CMS/CDC Up To Date Clarifications: (SNF/AL)

The Centers for Disease Control and Prevention (CDC) recently updated guidance regarding the definition of “Up To Date” as it applies to COVID-19 vaccinations. These changes have created a number of questions as to how and when this definition will be applied from a regulatory standpoint. The Centers for Medicare & Medicaid Services (CMS) has shared that currently, subject to further change at any time, the following definitions apply:

• CDC recommendations. CDC recommends that everyone over 12 years of age have one of the new bivalent boosters to be considered up to date. These recommendations should be viewed as best practice from a scientific standpoint, not as minimum regulatory requirements for survey purposes.
• Survey expectations for COVID-19 restrictions. For requirements based on vaccination status, such as routine staff testing and resident quarantine, CMS only requires a single monovalent booster for the person to be deemed up to date. CMS does not mandate additional booster shots or the bivalent vaccine for any COVID-19-related requirement that turns on up-to-date status. CMS does support the CDC recommendations that bivalent boosters reflect best practice.
• CMS vaccine mandate. The vaccine mandate for all SNF staff members remains tied to completing only the initial vaccination series. The vaccination mandate was released in regulatory guidance prior to booster recommendations and has not been updated by CMS since initial release.