The CMS interim final rule (IFR) requiring skilled nursing facilities, nursing facilities, and ICF-IIDs to establish a policy ensuring that all eligible staff be vaccinated for COVID-19 or request a medical or religious exemption outlines a two-phase policy. AHCA/NCAL has developed a template policy and procedures (P&P) document for members.  

The implementation dates for this rule are as follows: 

• Phase 1 – December 6, 2021: Staff must have received at least the first dose of a two-dose COVID-19 vaccine or a one-dose COVID-19 vaccine.
• Phase 2 – January 4, 2022: Staff must be fully vaccinated, except staff who have been granted exemptions, or those whom COVID-19 vaccination must be temporarily delayed as recommended by the CDC due to clinical precautions and considerations.  

It is important that providers put policies and procedures in place now to come into compliance with these requirements. To assist members, AHCA/NCAL has developed a template P&P that members can personalize to meet their needs. Note that this P&P document will be updated once CMS has released its interpretive guidance.