Medicare Compliance & Reimbursement

Some Medicare- and Medicaid-certified providers, suppliers, and facilities are required to follow through on the Centers for Medicare & Medicaid Services (CMS) COVID-19 vaccination mandate — and some are not.

Here’s a list of the types of Medicare and Medicaid providers, suppliers, and facilities that the COVID-19 rule affects, according to CMS guidance:

Ambulatory Surgery Centers

Clinics, Rehabilitation Agencies, and Public Health Agencies as Providers of Outpatient Physical Therapy and Speech-Language Pathology Services

• Community Mental Health Centers
• Comprehensive Outpatient Rehabilitation Facilities
• Critical Access Hospitals
• End-Stage Renal Disease Facilities
• Home Health Agencies
• Home Infusion Therapy Suppliers
• Hospices
• Hospitals
• Intermediate Care Facilities for Individuals with Intellectual Disabilities
• Long Term Care facilities
• Programs for All-Inclusive Care for the Elderly Organizations (PACE)
• Psychiatric Residential Treatment Facilities (PRTFs)
• Rural Health Clinics/Federally Qualified Health Centers

If your organization operates in these states — CA, CO, CT, DE, FL, HI, IL, ME, MD, MA, MI, MN, NV, NJ, NM, NY, NC, OR, PA, RI, TN, VT, VA, WA, WI — or U.S. territories, then you fall under CMS enforcement and you must comply with the requirement.

The injunction stands in these states — AL, AK, AR, AZ, GA, ID, IN, IA, KS, KY, LA, MS, MO, MT, NE, NH, ND, OH, OK, SC, SD, TX, UT, WV, WY — thus, you are not currently impacted by the CMS vaccination rule.

Important: Remember, the mandates could change on a dime, so preparation is key. Plus, even if you’re not covered by the CMS rule, you’re likely covered by the Occupational Health and Safety Administration (OSHA) one if you meet size requirements (see story, p. 5).