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Association Comments on CMS Vaccination Rule

America’s Essential Hospitals has submitted comments to the Centers for Medicare & Medicaid Services (CMS) on the agency’s interim final rule requiring COVID-19 vaccination for health care providers as a condition of participating in Medicare and Medicaid.

The association emphasized its members’ commitment to vaccination as the best way to protect patients and keep caregivers safe. However, given the uncertain outcome of pending litigation related to the Biden administration’s vaccine mandate, the association requested CMS provide additional time for hospitals to comply.

America’s Essential Hospitals also asked that CMS:

  • issue interpretive guidance as soon as possible to improve hospitals’ ability to comply with the vaccination requirements;
  • clarify work restrictions for providers making plans in consideration of staff who are not fully vaccinated, with a goal of preserving workforce levels;
  • further examine the impact of booster shot recommendations on the vaccination requirements under the rule and monitor for potential changes to the “fully vaccinated” definition; and
  • take a flexible approach to its survey process if a hospital experiences a COVID-19 surge or workforce shortages.

Contact Senior Director of Policy Erin O’Malley at or 202.585.0127 with questions.


About the Author

Maryellen Guinan is a principal policy analyst at America's Essential Hospitals.

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