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Federal Vaccine Requirements for Healthcare Settings


Last week the Biden administration announced a series of initiatives related to requiring the COVID-19 vaccination for all employees of certain businesses. We have heard from several OSMA members since the President’s announcement, and we're here to help better depict how practices and employees will be impacted.


Based on the elements outlined in the announcement, there appear to be two new regulations that might impact the employees in your healthcare setting:

The first is a directive for the Occupational Safety and Health Administration to oversee enforcement of a vaccine requirement for all workers in business with more than 100 employees.

The second is a directive for the Centers for Medicare and Medicaid (CMS) to oversee enforcement of a vaccine requirement for all workers in healthcare facilities that received Medicare or Medicaid funding. Both OSHA and CMS are in the process of drafting rules that will be used to guide and enforce the requirement. We anticipate draft rules being available for comment in mid October with final rules in place by the end of the year. Until the specifics of the rules are released, it will be difficult to assess if and how your healthcare setting will be impacted. As soon as the drafts are released we will send them to OSMA members.

A reminder, OSHA currently has a COVID-19 healthcare emergency temporary standard (ETS) that might be applicable to your practice or healthcare facility—particularly if you have more than 10 employees. These might be updated with the new directives, but until then, a detailed FAQ is available about the current requirements.

As more information is released regarding specific vaccine requirements at the federal or state level we will let you know.

Additional Resources:

White House Announcement Regarding Vaccine Requirements

CMS Press Release Regarding Vaccine Requirements and Rulemaking Process

OSHA Current FAQ on Healthcare Emergency Temporary Standards (ETS)


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