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CMS and OSHA Release Rules Related to Employee Vaccine Requirements


Today, the Center for Medicare and Medicaid Services (CMS) released its Interim Final Rule (IFR) regarding vaccine requirements for facilities receiving Medicare and Medicaid funds. Below is a short overview and summary regarding how your practice might be impacted and additional resources for you to review. If your practice is over 100 employees, you will also be impacted by the Emergency Temporary Standard (ETS) issued by the Occupational Safety and Health Administration (OSHA) requiring employers with 100 or more employees to ensure each of their workers is fully vaccinated or tests for COVID-19 on at least a weekly basis. Resources related to these standards are also provided below.

CMS Interim Final Rule (IFR) - Vaccine Requirement Overview

  • Type of Facility Impacted: The facility types covered by the CMS IFR are hospitals, ambulatory surgical centers, dialysis facilities, home health agencies, and long-term care facilities. This regulation does not apply to physician offices (unless part of a larger system) because they are not subject to CMS health and safety regulations.
  • Individuals Impacted: The requirement applies to both clinical and non-clinical staff at these facilities, including: employees, students, trainees, and volunteers.  Additionally, this also includes individuals who provide care, treatment, or other services for the facility and/or its patients under contract. It also applies to physicians admitting and/or treating patients in a facility. Staff who are not vaccinated because of religious or medical reason have to show valid proof and the facility has to keep this information on file. The regulations do address a process for people who have to delay vaccinations because of a current COVID infection. Staff who have had a previously documented COVID infection are NOT exempt. Natural immunity does not apply.
  • When: Workers must be fully vaccinated –either two doses of Pfizer or Moderna, or one dose of Johnson & Johnson – by January 4, 2022. The facility must have a plan developed to address vaccination and exemption record keeping by December 5, 2021.


OSHA Interim Final Standard (IFR) – Vaccine Requirement

OSHA Vaccine Requirement Overview Website

OSHA Vaccine Requirement FAQ


The OSMA will continue to review and monitor the implementation of the rules. If you have questions, please contact us at


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