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Public Sector Application of CMS' COVID-19 Health Care Vaccination Rule

January 24, 2022

Key Takeaways:

Since we published our January 14 alert on the Supreme Court's rulings on the OSHA and Centers for Medicare & Medicaid Services' (CMS) vaccination mandates, we have heard several questions about the impact of the CMS COVID-19 health care vaccination rule on various public sector entities either receiving Medicare and Medicaid funding or providing health-related services to the public, including ambulance and EMS services. We also have been asked whether employees of third-party contractors to public entities are subject to the rule.

CMS has provided helpful FAQs addressing these questions.

Scope and Application of the Interim Rule

State and Regional Guidance

State and local law may impose different regulations or guidance (e.g., legislative action, executive order, health department order) that can go beyond the rule. The rule is not a limit. 

Miller Canfield will continue to monitor new developments concerning the CMS' interim rule. If you have any questions about these developments or how they may impact your workplace, please contact the authors of this alert or your Miller Canfield attorney.

This information is based on the facts and guidance available at the time of publication and may change as the agency receives comments and/or updates its guidance.