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CMS Vaccine Mandate: Compliance Dates Clarified


As stated in our previous client alert, the Centers for Medicare and Medicaid Services (CMS) set compliance dates for the vaccine mandate in all of the states where the injunction had been lifted, which became official for those states when the United States Supreme Court upheld the mandate, determining that CMS acted within its authority. CMS has now officially clarified compliance dates for those states where the CMS vaccine mandate was formerly blocked.

What Has Not Changed:

If your regulated facility is located in California, Colorado, Connecticut, Delaware, Florida, Hawaii, Illinois, Maine, Maryland, Massachusetts, Michigan, Minnesota, Nevada, New Jersey, New Mexico, New York, North Carolina, Oregon, Pennsylvania, Rhode Island, Tennessee, Vermont, Virginia, Washington, or Wisconsin, the compliance dates remain the same: all staff must be vaccinated with the first dose no later than January 27, 2022, and with the second dose as applicable by February 28, 2022.

What Has Changed:

If your regulated facility is located in Alabama, Alaska, Arizona, Arkansas, Georgia, Idaho, Indiana, Iowa, Kansas, Kentucky, Louisiana, Mississippi, Missouri, Montana, Nebraska, New Hampshire, North Dakota, Ohio, Oklahoma, South Carolina, South Dakota, Utah, West Virginia, or Wyoming, you must mandate all staff (broadly defined as discussed in our prior alerts) to be vaccinated with the first dose no later than February 13, 2022, and with the second dose as applicable by March 15, 2022.

And Then There Is Texas

Finally, Texas remains an outlier. On January 19, 2022, a federal judge dismissed the Texas challenge, including the only injunction that was left remaining after the Supreme Court’s decision on January 13, 2022. It’s still unclear when Texas facilities will have to comply with the mandate, but they are explicitly excluded from the January 14, 2022 guidance.

Bottom Line:

Regulated health care entities - get busy with those policies, procedures, vaccination clinics, and exemption processing! The details are in our prior client alerts below:

Quarles & Brady will continue to monitor developments with respect to the CMS Rule and the latest COVID-related recommendations from the CDC. If you are seeking further guidance or if you have any specific inquiries, please contact your local Quarles & Brady attorney, or:

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