I extracted from Biden’s “Action Plan” (Requiring All Employers with 100+ Employees to Ensure their Workers are Vaccinated or Tested Weekly) and the State mandate (Colorado Board of Health Approves Vaccine Mandate for Licensed Healthcare Facilities)
Federal: "Medical practices" are not specifically called out with "hospitals, dialysis facilities, ambulatory surgical settings, and home health agencies".
Federal: "These requirements will apply to approximately 50,000 providers", apparently excluding medical group practices.
Federal: Extends to "staff who are not involved in direct patient care".
State: “Notably, the Board does not have authority over individual health care practitioners or staff, primary care offices, or urgent care locations.”
It seems there's a clear distinction between "services" and "facilities" with the mandate focused on "facilities".
My question: are group medical practices with less than 100 employees excluded from the mandate?
My response: group medical practices . . . at least those with less than 100 FTEs, are exempt.
What’s your response?
I may have answered my own question. Most group medical practices are exempt:
Posted 3 days ago
Good morning MGMA members,
MGMA Government Affairs is bringing you two important updates that have the potential to impact your practice.
OSHA Vaccination and Testing Policy for Employers with 100+ Employees
President Biden announced a "six-pronged" national strategy to combat COVID-19. According to the plan, the Department of Labor's Occupational Safety and Health Administration (OSHA) is set to draft another emergency temporary rule requiring employers with more than 100 employees to verify that their workforce is fully vaccinated or require unvaccinated workers to produce a negative test result on a weekly basis. Once OSHA releases the rule, MGMA will review and share the details. At the moment, we are working with limited information until we read the rule.
Biden Administration to Expand Vaccination Requirements for FacilitiesThe Biden administration announced that it will require COVID-19 vaccination of staff within all Medicare and Medicaid-certified facilities. Keep in mind this would apply to facilities as defined here. CMS is drafting an Interim Final Rule with Comment Period (IFR) that is expected to be issued in October 2021. Once CMS releases it, MGMA will review and share our takeaways.
Please let us know if you have any questions.
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