COVID-19 CMS Vaccination Requirements - Clinical Contraindications / Medical Exemption Documentation for Deemed Organizations
Are organizations required to go back and obtain missing elements of the CoP/CfC required documentation for clinical contraindications or medical exemptions obtained prior to the effective date of the interim final rule?
Any examples are for illustrative purposes only.
Yes. It has been confirmed with CMS that organizations that accepted any clinical contraindication or medical exemption documentation for an eligible individual prior to the Centers for Medicare and Medicaid Services CMS Interim Final Rule (IFR) published on December 28, 2021, are required to retrospectively obtain any of the required missing documentation. Organizations that accepted clinical contraindication or medical exemption documentation for an eligible individual AFTER the IFR was published are expected to update the information with the required medical exemption elements as outlined in the IFR.
Examples of required documentation that may be missing include:
Yes. It has been confirmed with CMS that organizations that accepted any clinical contraindication or medical exemption documentation for an eligible individual prior to the Centers for Medicare and Medicaid Services CMS Interim Final Rule (IFR) published on December 28, 2021, are required to retrospectively obtain any of the required missing documentation. Organizations that accepted clinical contraindication or medical exemption documentation for an eligible individual AFTER the IFR was published are expected to update the information with the required medical exemption elements as outlined in the IFR.
Examples of required documentation that may be missing include:
- Signing and dating by a licensed practitioner
- Information specifying which of the vaccines are clinically contraindicated
- The recognized clinical reasons for the contraindication
- A statement recommending the staff member be exempt
For additional information, please visit the following CMS website:
CMS: Guidance for the Interim Final Rule - Medicare and Medicaid Programs; Omnibus COVID-19 Health Care Staff Vaccination
CMS: Guidance for the Interim Final Rule - Medicare and Medicaid Programs; Omnibus COVID-19 Health Care Staff Vaccination
Manual:
Hospital and Hospital Clinics
Chapter:
Leadership LD
New or updated requirements last added: May 18, 2022.
New or updated requirements may be based on revisions to current accreditation requirements, regulatory changes, and/or an updated interpretation in response to industry changes. Substantive changes to accreditation requirements are also published in the Perspective Newsletter that is available to all Joint Commission accredited organizations.
Last reviewed by Standards Interpretation: May 18, 2022
Represents the most recent date that the FAQ was reviewed (e.g. annual review).
First published date: April 02, 2022
This Standards FAQ was first published on this date.
This page was last updated on May 18, 2022
with update notes of: Reflects new or updated requirements
Types of changes and an explanation of change type:
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Review only, FAQ is current: Periodic review completed, no changes to content. |
Reflects new or updated requirements: Changes represent new or revised requirements.