Vaccine Mandate for Contractors & Vendors (SNF)

As members work to establish their policies and procedures for the upcoming Centers for Medicare & Medicaid Services (CMS) COVID Vaccine Mandate, don’t forget to reach out to contracted service providers to confirm how vaccine verification will be handled.

Many contracted service providers currently utilized in nursing facilities are included under the CMS mandate; however, some of those commonly used fall outside CMS jurisdiction. Specifically, Emergency Management Services (EMS), including wheelchair transport, and Fire Safety staff are governed through the Department of Transportation (DOT) rather than CMS, and as such are not required to adhere to the vaccine mandate. In addition, consider the various suppliers and others you have existing contracts or arrangements with who may fall outside the CMS requirements. 

Members should reach out to suppliers and others providing routine services to determine how they will meet your required compliance, and how documentation of compliance will be shared and communicated with your team. Under the CMS guidance, you may rely on the service provider to attest to their employees meeting the vaccine or exemption requirements and to maintain documentation for their employees, however the service provider must be willing to share documentation with you upon short notice when needed for compliance verification.