CMS Releases Guidance on Implementing Additional Precautions for Unvaccinated Staff Under CMS Vaccine Mandate

The Centers for Medicare and Medicaid Services (CMS) staff vaccination rule requires facilities to take additional precautions for those staff who remain unvaccinated due to a medical/religious exemption or newly hired staff who only have the first dose of the two-dose series. CMS provides a list of additional precautions in QSO memos QSO-22-07-LTC, QSO-22-09-LTC, and QSO-22-11-LTC.
It is important to keep in mind that facilities are not required to follow all the precautions listed by CMS in the QSO memo. However, they should be intentional about establishing appropriate policies around additional precautions and take a layered approach based on risk of COVID-19 transmission to residents they serve. For example, facilities may choose to test all unvaccinated staff at a higher frequency than required by CMS or CDC guidance, but only require unvaccinated staff with direct contact with residents to wear N95 masks.
In addition, facilities may want to reassign unvaccinated frontline caregivers to residents who are not at particularly high risk for negative outcomes due to COVID-19.

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