Medicare & Medicaid Requires COVID Vaccines for Health Care Workers


What You Need to Know About the CMS Update

As many of you know, health care organizations across the country have begun to issue requirements for COVID-19 vaccinations. These regulations not only protect health care workers but also create a consistent standard that assures patients of the vaccination status of those delivering care.

On November 4, 2021 the Centers for Medicare and Medicaid (CMS) published an interim final rule requiring employees working at facilities enrolled with Medicare and Medicaid to be fully vaccinated by January 4, 2022. As a provider participating in these programs, Rockingham County Rehabilitation and Nursing Center (RCRNC) must adhere to this new regulation. CMS estimates that these new requirements will apply to approximately 76,000 providers and will cover over 17 million health care workers.

In anticipation of this decision, RCRNC and the County Commissioners developed a mandatory vaccination policy in October 2021. Per the RCRNC Mandatory Employee COVID-19 Vaccination Policy, all employees must be fully vaccinated by December 11, 2021 and submit proof of vaccination to Human Resources by Monday December 13, 2021.

RCRNC and CMS believe that the best way to overcome COVID-19 is with vaccinations, which have been proven to be safe and effective. We believe this policy will safeguard our employees, residents, and the community at large. This new CMS rule further supports the Commissioner’s decision to require all RCRNC and Ernest P. Barka Assisted Living Community employees, consultants, contractors including vendors, volunteers and caregivers and any other County employee who provides care and services to facility residents, interns, and students to be vaccinated against the COVID-19 virus. We trust that this requirement will drive down infections and stabilize the nationwide health care system.

What is CMS?

The Centers for Medicare & Medicaid Services is an agency within the U.S. Department of Health and Human Services (HHS). They administer and oversee programs including Medicare, Medicaid, the Children’s Health Insurance Program, and the state and federal health insurance marketplaces.

RCRNC is guided by CMS and required to adhere to CMS rules.


The CMS policy requires providers to ensure all eligible staff get at least one dose of the COVID-19 vaccine prior to providing care or any other services by December 5th and to be fully vaccinated by January 4, 2022. The RCRNC policies will take precedence over the new CMS rule. We will continue to require employees to follow the Rockingham County timeline and policies already set in place.

RCRNC continues to host mobile vaccine clinics to ensure our employees have the easiest access possible to the vaccine. The next vaccine clinic is scheduled for Monday, December 20, 2021 at 9:30 am. All shots will be available.

How do we define fully vaccinated?

Individuals are considered fully vaccinated 14 days after their second Moderna or Pfizer shot and 14 days after a single shot of Johnson & Johnson.

Who must get vaccinated?

The rule applies to all current and new staff members eligible for the vaccine. This includes facility employees, licensed practitioners, students, trainees, volunteers and contracted staff, regardless of patient interaction.

The regulation does not apply to telehealth workers who are fully remote.


CMS provides for exemptions based on medical conditions and religious beliefs. Exemption requests will be reviewed by the Rockingham County Human Resources Department.

Exempt staff will be provided with appropriate accommodations. RCRNC has the authority to determine the best type of accommodations to minimize risk of transmission. 

A history of COVID-19 infection or positive antibody screen is not considered a substitute for vaccination under this policy.


The CMS rule does not provide an option for healthcare workers to be tested on a weekly basis in lieu of being fully vaccinated.


The CMS rule will be enforced through established state survey agencies and accrediting organizations. Facilities found out of compliance will be cited and possibly terminated from the Medicare and Medicaid programs.

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