Who gets stuck…

As things start to even out (at least somewhat) in the pandemic (I can’t say “subside” yet, but I am hopeful that perhaps with the onset of spring we’ll get to the point where that is an accurate descriptor), there’s something of an opportunity to look at some of the measures that have been put in place by our friends at the Centers For Medicare & Medicaid Services. This week (and I can’t guarantee that this is going to be the first in series, though CMS certainly casts a very long shadow over us all), I thought we’d touch a little bit on the vaccination piece of the puzzle that (at least to me) it seems to have the greatest potential for compliance challenges.

Now that the legal ramifications over what CMS can and cannot bring to bear over healthcare organizations and the vaccination requirements are applicable across the board. (And what a board it is: https://www.cms.gov/medicareprovider-enrollment-and-certificationsurveycertificationgeninfopolicy-and-memos-states-and/guidance-interim-final-rule-medicare-and-medicaid-programs-omnibus-covid-19-health-care-staff-0; this link is still active though it pre-existed the Supreme Court decision).

There’s a lot of ground for which hospitals and other healthcare organizations are responsible. Recognizing the allowances for exemptions, etc., (“staff who have been granted  exemptions  to  the vaccination  requirements  of  this  section,  or those  staff  for  whom  COVID-19 vaccination  must  be  temporarily delayed, as recommended  by  CDC,  due to  clinical  precautions  and considerations), the following groups are in the mix for vaccinations:

1. Hospital employees;
2. Licensed practitioners;
3. Students, trainees, and volunteers; and
4. Individuals who provide care, treatment, or other services for the hospital and/or its patients, under contract or by other arrangement.

The folks who don’t “rule in” work would be:

• Staff who exclusively provide telehealth or telemedicine services outside of the hospital setting and who do not have any direct contact with patients and other staff specified above; and
• Staff who provide support services for the hospital that are performed exclusively outside of the hospital setting and who do not have any direct contact with patients and other staff specified above.

On the face of it, it seems like a fairly reasonable split on things, but in looking at group (ii) under the folks who are not required to be vaccinated, that last statement sends a bit of a chill down my spine (and not just because it’s kind of cold in the Northeast). How do you figure out which folks providing services “outside of the hospital setting” don’t have direct contact with the folks who are required to be vaccinated?

I understand the desire to keep folks protected, but this seems to complicate things to a degree that almost makes it unmanageable, though perhaps I am overthinking the practical aspects of implementation and compliance. I have no doubt that further work will be done to reduce the burdens associated with preventing a significant recurrence of COVID and maybe we get to a point where we are allowed to work this out in our own fashion, so to speak. And it may be that since they’ve suspended the focus survey of programmatic elements relating to the pandemic, keeping track of all this is not as onerous as it seems. I guess we’ll have to see how things unfold over the coming weeks and months, but if anyone has a shareable experience, please let me know.

About the Author: Steve MacArthur is a safety consultant with The Greeley Company in Danvers, Mass. He brings more than 30 years of healthcare management and consulting experience to his work with hospitals, physician offices, and ambulatory care facilities across the country. He is the author of HCPro's Hospital Safety Director's Handbook and is contributing editor for Healthcare Safety Leader. Contact Steve at stevemacsafetyspace@gmail.com.