The American Hospital Association is calling on the Biden administration to ensure its upcoming interim final rule regarding healthcare workforce vaccination is wide reaching, transparent and in line with similar requirements from other federal agencies.
In a public comment released earlier this week, AHA reaffirmed its support for a policy announced by the Biden administration that requires provider organizations enact a mandatory workforce vaccination policy as a condition of participation in Medicare and Medicaid.
Although set to be unveiled in October, the group urged the Centers for Medicare and Medicaid Services (CMS) to hasten the interim final rule’s release so that hospitals have more time to prepare and as additional encouragement for still-unvaccinated healthcare workers.
“At a time when hospitals remained strained by ongoing surges in COVID-19 hospitalizations, issuing the [interim final rule] and interpretive guidance quickly will help minimize disruptions to the field, and provide hospitals with the clarity and stability they need to implement the policy,” AHA wrote in its comment to CMS.
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The AHA was also concerned that unvaccinated employees may simply jump ship to other areas of the healthcare industry that aren’t bound by CMS’ requirement.
Keeping the industry’s labor shortage and potential interruptions in care, the group asked CMS to apply its policy equally across all Medicare-regulated health providers, including federally-qualified health centers, community health centers and physician practices.
Making the requirement as broad as possible would minimize the possibility “that healthcare providers do not compete for a limited labor pool based on whether particular types of entities are required to have vaccination mandates,” the industry group wrote.
AHA’s full letter went on to outline potential pain points related to the interpretation of the compliance requirement, enforcement and potential conflicts with other federal agencies. To counter these concerns, the industry group recommended that CMS:
- Issue a compliance deadline roughly two- to three-months from the release of the interim final rule
- Adopt a progressive enforcement approach that only escalates consequences “when hospitals fail to engage with CMS to seek guidance and assistance”
- Permit enforcement flexibility in the event of an unexpected vaccine supply shortage
- Issue any interpretive guidance “as close to concurrently with the interim final rule as possible
- Provide interpretive guidance on consistent application of employees’ medical and religious exceptions
- Measure compliance using the same vaccination quality measures that are planned for reporting through the National Healthcare Safety Network
- Work with the Occupational Safety and Health Administration (OSHA), the Equal Employment Opportunity Commission (EEOC) and others to build a single set of federal requirements.
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AHA noted that as of Sept. 27, 2,549 hospitals and health systems had rolled out plans for their own mandatory vaccination policies that often center on different deadlines, cutoffs and exemptions. Some states and other municipalities have also gone forward with their own healthcare worker vaccination mandates, underscoring the need for the federal government to communicate a clear and unified approach.
“In implementing a national regulatory mandate for health care facilities to vaccinate their personnel, CMS should ensure its policy is feasible, transparent and fair for all health care providers that are subject to it,” AHA wrote.