BriggsNetNews

Mary Madison, RN, RAC-CT, CDP 
Clinical Consultant – Briggs Healthcare

CMS conducted a National Stakeholder Call the afternoon of Thursday, November 4, 2021 – just hours after the posting of an Interim Final Rule (with comments). I quickly blogged to provide the call notification and the information we were given at that time so providers could get on the call.  There were 10,000 individuals on the Zoom call which was the maximum capacity.

CMs quickly posted the COVID-19 Health Care Staff Vaccination IFC-6 National Stakeholder Call Slides (PDF) this morning (11/5) along with the COVID-19 Health Care Staff Vaccination IFC-6 National Stakeholder Call Video (just a hair over 39 minutes in length).  The video, slides and CMS Omnibus Staff Vax Requirements (PDF) are all found on the CMS Current Emergencieswebpage, beneath the Clinical & technical guidance: For all health care providers section.  The 214-page Omnibus COVID-19 Health Care Staff Vaccination IFC should also be on your to-review/to-do list. I strongly encourage you to download the slides, listen to the YouTube video, review the Q&A document and the IFC itself.

The presenters for this National Stakeholder Call spoke to CMS’ goal of the healthcare system needing to be as safe as possible for all (residents and staff). We were also instructed to look to the just-released CMS rule on vaccination as that supersedes the OSHA rule for HC facilities. The presenters stayed close to the verbiage on the slides for the call with the Q&A at the end coming from question in the Omnibus Staff Vax Requirements document. (I asked 3 questions on the Zoom platform, but they were not addressed.)

The CMS IFC-6 covers 15 entities for compliance which equates to 76,000 suppliers and providers and 17 million healthcare workers. It’s important to note the primacy statements on slide 14. CMS’ IFC-6 pre-empts any state law under the U.S. Constitution. Also pay close attention to the 2 phases of this Interim Rule, found on slides 6 and 15.  We have work to do!