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CMS Vaccine Mandate: New Deadlines
/in COVID-19By Kim Stanger
On January 13, 2022, a divided Supreme Court vacated the injunctions that applied to CMS’s vaccine mandate in 24 states, thereby allowing CMS to enforce its mandates in all states except Texas.1 (https://www.supremecourt.gov/opinions/21pdf/21a240_d18e.pdf). Here are key points for providers seeking to comply with the mandate.
Deadlines for Compliance. The effective deadlines for compliance run from the date CMS issued its relevant compliance guidance to survey agencies. For facilities in states that were not subject to an injunction, CMS issued its guidance on December 28, 2021. (QSO-22-07-ALL, available at https://www.cms.gov/files/document/qso-22-07-all.pdf). For facilities in states that were subject to an injunction (i.e., Alabama, Alaska, Arizona, Arkansas, Georgia, Idaho, Indiana, Iowa, Kansas, Kentucky, Louisiana, Mississippi, Missouri, Montana, Nebraska, New Hampshire, North Dakota, Ohio, Oklahoma, South Carolina, South Dakota, Utah, West Virginia, and Wyoming), CMS issued its updated guidance on January 14, 2022. (QSO-22-09-ALL, available at https://www.cms.gov/files/document/qso-22-09-all-injunction-lifted.pdf). As set forth in the guidance, the deadlines are as follows: Read more
No Surprise Billing Rules: Good Faith Estimates and Unscheduled Services
/in Providers, Reimbursement & CollectionsBy Kim Stanger
The No Surprise Billing Rules took effect January 1, 2022, but many questions remain, including if and to what extent the new rules for good faith estimates apply to items or services that are provided to self-pay patients on an unscheduled basis, such as emergency, urgent care, or walk-in patients. Read more
No Surprise Billing Rules: Checklist for Providers
/in Compliance, ProvidersBy Kim Stanger
Many providers make the No Surprise Billing Rules more complicated and expansive than they are. To help healthcare providers and facilities understand, implement and monitor compliance with the new rules, Holland & Hart has prepared a short guide and checklist for compliance, available here.
Federal Court Stays CMS Mandate Nationwide
/in COVID-19By Kim Stanger
Today, the federal district court in Louisiana issued a preliminary injunction staying the CMS vaccine mandate nationwide (except for the 10 states subject to yesterday’s injunction in Missouri). A copy of the Order is here. Read more
CMS Vaccine Mandate for Healthcare Workers: Resources for Preparing Your Policies
/in Compliance, COVID-19By Kim Stanger
Under the Centers for Medicare & Medicaid Services (CMS)’s new vaccine mandate for healthcare workers, facilities must draft and implement policies and procedures by December 6, 2021 to ensure covered personnel are fully vaccinated or exempted by January 4, 2022. (86 FR 61573). That does not give facilities much time, but here are some resources that may help with compliance. (This alert supplements our summary of the CMS and OSHA mandates.) Read more