CMS Vaccine Mandate & Ombudsman Program (SNF)

Although the Centers for Medicare & Medicaid Services (CMS) vaccine mandate impacts all providers participating in Medicare & Medicaid, it is not applicable to the Ombudsman’s program. During discussions with Evan Shulman at CMS, the Ombudsmen program has clarified that long term care (LTC) Ombudsmen are not considered staff or visitors, but rather have a role related to health oversight. Given the LTC Ombudsman program is not regulated by CMS, the CMS guidance does not apply to LTC Ombudsmen. 

Ombudsmen are expected to participate in the health screening process when entering a facility, as well as follow infection control practices (hand hygiene, distancing, masking at all times, etc.) and they are not to visit or enter a facility if they feel ill or have been exposed to COVID.  Like visitors entering the building, they can be asked about vaccination status or testing results, however these status checks are not required for entering the building. Ombudsmen are also advised to use their best judgement and avoid in person visits to COVID affected residents, instead utilizing technology or other alternate means of communication to conduct these visits.