Changes to the Federal Contractor Vaccine Mandate
Summary
Federal contractor employers subject to the new COVID vaccine requirements were previously given a December 8, 2021 deadline to show that all covered employees are fully vaccinated. However, with the release of new vaccine requirements from the Occupational Safety and Health Administration (OSHA), the deadline for federal contractors has been extended to match with the deadline in the OSHA requirements. The Centers for Medicare & Medicaid Services (CMS) within the Department of Health and Human Services (HHS) has also announced the details of that agency’s requirements for the vaccination of all health care workers at facilities that accept Medicare and/or Medicaid reimbursement. To the extent that the CMS requirements and those for federal contractors differ, health care providers would be wise to focus on the CMS requirements as they are more comprehensive, provide more protection for more people, and would likely have more dire consequences for non-compliance as the loss of Medicare and/or Medicaid reimbursement could be devastating to the business. As always, if you have questions or concerns about this or any other requirements for federal contractor employers, feel free to contact us at BCGi@Biddle.com.
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