Healthcare organizations (HCO) can also use the portal to submit a question about an existing PHE or related issue, according to the January 11 memo QSO-21-11-ALL.
Your blanket waivers surrounding healthcare operations during the current COVID-19 crisis are now good through April 21, 2021.
Health and Human Services Secretary Alex M. Azar II has extended the Public Health Emergency (PHE), first declared almost a full year ago, for another 90 days, effective January 21.
CMS has also tried to make it easier to ask for an 1135 waiver that is not part of the now 42-page list of blanket regulatory flexibilities that the federal agency instituted to help hospitals and other facilities cope with the surge of COVID-19 patients.
There is now a CMS PHE Emergency Web Portal “designed to reduce burden and streamline the submissions of 1135 waiver requests/inquiries in a simple-to-use format,” using a computer or mobile device with Chrome or Firefox as the preferred browser, according to the announcement posted on CMS’ webpage of memos to state and regional offices.
Healthcare organizations (HCO) can also use the portal to submit a question about an existing PHE or related issue, according to the January 11 memo QSO-21-11-ALL.
The portal will assist “in expediting review of submissions, triages requests or inquiries, and tracks/reports on a national scale,” according to CMS.
You do not have to reapply for any of the blanket waivers already on the list, says the agency.
The portal is designed to be easier for HCOs, but also will take a load off the state and regional CMS offices that have been fielding individual waiver requests as well as general questions about the PHE for more than a year.
“If you or your organization have a question for CMS regarding a PHE, please visit the 1135 web-based portal to submit a PHE-related Inquiry. If you or your organization would like to request an 1135 waiver during a PHE, then also visit the web-based portal to submit your request,” says CMS.
CMS has long offered hospitals the ability to ask for flexibilities on meeting Conditions of Participation and other regulatory requirements during PHEs through 1135 waivers. The current PHE was first declared in late January 2020, retroactive to January 27.
While the list of blanket waivers came later, they are tied to the time period of the PHE. This is the fourth renewal of the original PHE declaration. While this extension — and the 1135 waivers allowed under it — goes through April 21, the PHE can be ended earlier if HHS decides the emergency is over.
According to HHS, “A PHE declaration lasts until the Secretary declares that the PHE no longer exists or upon the expiration of the 90-day period beginning on the date the Secretary declared a PHE exists, whichever occurs first. The Secretary may extend the PHE declaration for subsequent 90-day periods for as long as the PHE continues to exist, and may terminate the declaration whenever he determines that the PHE has ceased to exist.”
The Joint Commission (TJC) is asking for feedback on proposed changes to hospital requirements on resuscitation and the long-awaited new elements of performance on workplace violence prevention.
The revisions on resuscitation policies and protocols were posted January 11 and TJC will accept comments through February 22.
Long-discussed and first announced last fall, the new and revised requirements on workplace violence prevention are in the Environment of Care, Human Resources, and Leadership standard chapters.
The new requirements will mandate that hospitals:
Conduct an annual work-site analysis that includes any workplace violence events and take action on that analysis.
Provide training, education, and resources for the prevention of workplace violence to leadership, staff and licensed practitioners with 90 days of hire, annually, and ongoing as needed.
And that leadership must designate an individual to develop a multidisciplinary team to develop policies and procedures to prevent workplace violence, a process for reporting events and a process to follow-up and provide support to victims and witness. Incidents must also be reported to the governing body.
The field review on resuscitative services actually is the second field review, according to TJC. The first review was in June-August 2020. Those proposed requirements were “revised based on public comments from the first field review and the updated 2020 American Heart Association Guidelines for CPR and ECC.”
The revisions on resuscitative services provides more detail on what is expected of the education and training of staff under Provision of Care standard PC.02.01.11, and creates a new standard under PC.02.01.20, under which hospitals are required to implement “processes for post-resuscitation care and recovery.”
Hospitals will also be required to collect data on cardiac arrests and resuscitative services, and have information analyzed by an interdisciplinary team, according to proposed revision to the Performance Improvement standards.
When civil unrest outside your doors threatens to come inside, be sure staff are trained on screening protocols for identifying people who should not be in your facility or on your property.
Whether it’s high school rivalries, gang activity, or even political unrest, hospitals should be prepared for patients from opposing sides to be in your emergency department (ED).
Frayed nerves from the pandemic will only serve to make things worse.
The reality of local civil unrest is now all too common, says Bryan Warren, MBA, CHPA, CPOI, a longtime hospital and healthcare security professional and now president and chief consultant of WarSec Security. Warren, who responded to questions by email, is also a past president of the International Association for Healthcare Security and Safety.
“Anytime that you are as open to the public as hospitals are, plus you are dealing with people that are not entirely rational, you run the risk of one person or group not agreeing with another. This is magnified when those persons are injured or under some type of additional stress, and you see it all the time in healthcare waiting areas,” notes Warren.
That stress is seen not just in the ED, “but also in maternity units as well as ICUs with end-of-life issues and estranged family members coming together for the patient’s sake,” observes Warren.
Lessons learned
Recently, the Department of Health and Human Services’ Assistant Secretary for Preparedness and Response (ASPR) updated its Technical Resources, Assistance Center, and Information Exchange (TRACIE) site with a four-page set of lessons learned in Minneapolis during the civil unrest after George Floyd died during a police arrest, an event caught on video and widely shared on social media.
According to Civil Unrest During a Pandemic: Notes From Minneapolis, most patients arrived in the ED via local emergency medical services. However, many people fleeing riot scenes sought safety in nearby hospitals and clinics.
Keeping opposing sides apart to ensure the civil unrest doesn’t follow people inside begins at your perimeters, advises Warren. Coordinate with your local law enforcement because you may need their help.
“All healthcare organizations should have in their policies and procedures some type of screening protocol which should begin at the perimeter of the facility to identify persons that clearly have no legitimate purpose being inside the building or on the property,” says Warren.
“Appropriate screening and visitor management can also help to differentiate between patients and family members and hopefully provide some direction regarding which waiting areas they will be assigned to (should there be indications that certain patients and their acquaintances may not coexist peacefully),” he says.
“For situations in which such indicators are not readily apparent, it is also important that the facility have a restricted access process so that even if persons of differing viewpoints end up inside the same waiting area, they would not be able to freely enter patient care units or staff-only areas of the facility while restricted access protocols were in effect,” Warren says.
Coordinate with local law enforcement
“This is also an instance in which a strong public/private partnership with local law enforcement is critical so that any persons causing a disruption or negatively impacting the facility’s ability to provide patient care can be quickly removed (within applicable legal and regulatory frameworks),” says Warren.
“Not all facilities have the capability to provide separate waiting areas for conflicting parties, so the provision of uninterrupted patient care must be the driving factor in enforcing such decisions, so the hospital is not perceived as ‘taking sides,’ ” he notes.
“For long-term patients, this might result in designated times of day or even days of the week for visitation,” he recommends. For instance, group A can visit Monday, Wednesday and Friday, group B on Tuesday, Thursday, and Saturday, and so on.
“But this is not feasible for emergencies or other dynamic situations. Healthcare organizations should make every attempt to clearly address expectations of conduct to those that are becoming disruptive and then have a plan in place should their removal or relocation be required,” says Warren.
The pandemic has frayed nerves. But it also has provided at least one benefit, notes Warren: “Healthcare facilities do not have nearly as many visitors as usual for patients (even emergency departments).”
That said, “any event that occurs within the community in which people are injured or even think they are injured (the walking worried, for example, protesters exposed to chemical agents) will involve the local hospital or healthcare provider and could create potential disruptions due to rival factions all showing up for treatment or visitation at the same location,” he warns.
“This is why guidelines not only for patient surge events, but also civil unrest events and their consequences should be included in an organization’s emergency preparedness plan,” he advises.
CMS continues to work with accreditation organizations (AOs) on providing some remote flexibilities in conducting surveys. But only through the COVID-19 public health emergency (PHE).
After that you will be expected to be ready for survey. There will not be a grace period.
In a December 22 email, CMS acknowledged the agency was working with AOs on remote surveys— but not beyond the PHE. After that, it’s operations as usual.
“CMS has not approved any virtual processes for use after the PHE. CMS will not be granting a recovery period at the end of the PHE. AOs are expected to resume normal survey activity based on guidance and any additional information we may provide,” according to the statement.
See more about which AOs will be providing remote full accreditation surveys in the February IAQ.
Trying to get anyone to wear a mask can be difficult during this ongoing COVID-19 pandemic. Maintaining infection control measures in a behavior health setting is even more challenging.
But you still have to. Given that reality, CMS has put together a 12-page list of frequently asked questions (FAQ) to help.
The Quality, Safety & Oversight Group (QSO) memo QSO-21-07-Psych Hospital, PRTF & ICF/IID, “COVID-19 Infection Control for Psychiatric and Intermediate Care Facilities for Individuals with Intellectual Disabilities (ICFs/IID),” was sent to CMS regional offices and state agencies on December 17, 2020.
According to the memo, the FAQs “are intended to provide guidance" in the following areas:
Promising practices, measurement, and mitigation strategies for infection control during the PHE
Use of isolation, cohorting and PPE
Intervention, mitigation, and training strategies
Transition and discharge during the PHE
Engaging family, caregiver, support personnel, and community resources
Available local, State and Federal resource guides and web links”
The FAQs are divided into several sections, such as “Addressing Refusal or Reluctance to COVID-19 Modifications” and “Challenging Behaviors, and Seclusion and Restraint.”
Set up clear communication with your hospital staff and remain open to feedback as you receive and administer the COVID-19 vaccines.
Work with supervisors and other leadership to schedule staff vaccinations and, if possible, work around shifts so that workers who do experience symptoms don’t have to cope with them while working.
Scheduling and communication may be two of the most important keys to having a success vaccination program, says Anurag Malani, MD, Medical Director, Infection Prevention & Antimicrobial Stewardship Programs, for St. Joseph Mercy Health System, which includes seven facilities in southeast Michigan.
St. Joe’s actually received its first batch of Pfizer-BioNTech vaccines on Thursday, December 17, about a day ahead of schedule, said Malani.
But within a few hours, the health system had employees scheduled for vaccination at 10 to 15 minute intervals, administering about 770 of the approximately 975 doses by Monday afternoon.
Overall, Mulani said he was amazed with how well things have gone so far.
St. Joe’s began by scheduling what they called their 1A tier of staffers who work closest to the COVID-19 patients: physicians, nurses, transporters, technicians, environmental services personnel or anyone working in a COVID unit, he said. (Yes, that includes the residents.)
The hospital is also taking staff from other facilities within their system who did not immediately get vaccines, he said.
The most important concern he has so far is making sure that the hospital is communicating with its staff, answering questions and ensuring that those who should get the vaccine get schedule for their first dose —and make a return trip for the second dose.
The vaccinations are not mandatory and there has been a lot of misinformation about the vaccines and their safety in the last few weeks, he said.
It’s important to address concerns and get as many people in for their immunization as possible, he said.
“The pandemic is not going to go away if it’s just healthcare workers” getting vaccinations “and it’s not going to go away if only half of your workers are taking it,” Malani said.
Communication is also important in getting those staffers back for their second dose, even if they had an adverse reaction to the first immunization, he said.
Like many vaccinations, the most typical symptom is discomfort at the site of the injection as well as headaches, fatigue and other general body aches. But those symptoms usually go away quickly, he said.
This is a two-shot immunization and won’t be effective if there’s not a second dose. Having said that, he did note that the most adverse symptoms are likely to happen after the second dose.
That’s why it will be important to keep open communication, urged Malani. While the immunizations are voluntary, Malani said supervisors should try to identify who is not getting the vaccine so that concerns can be addressed and questions answered.
Hesitancy about vaccinations is understandable, he said, given that historically some groups have been more impacted by others by the disease or problems with vaccinations.
But that’s all the more reason to reach and get those groups the information they need to make decisions, he said.
“Transparency and open dialogue is pretty important,” he said.
The U.S. government is shipping the Pfizer-BioNTech vaccine to various states, which will then be in charge of distributing the thermal containers to predesignated locations according to each state's vaccine rollout plan.
As you launch COVID-19 vaccine operations, experts caution: Freeze or chill, but do not shake.
Be extra careful with the vaccine and with the dry ice that will keep it cold – mishandling the dry ice can cause injury and possibly even death, warned Ramya Krishnan, senior project engineer, Device Evaluations, for ECRI, during the patient safety organization’s online Q&A session on Wednesday, December 16.
Also, think through how you will schedule and move patients through your facility, advised David Watson, vice president of ECRI’s European Operations. Watson is based in the United Kingdom where the first Pfizer-BioNTech vaccines were administered on December 8.
You will need space to take a patient history (including any previous allergic or anaphylactic reactions to food, drugs or insects) to administer the vaccine, to provide at least 15 minutes of observation for adverse reaction afterward, and an area to care for anyone who does have a reaction — all while maintaining the same social-distancing and infectious-disease precautions you’ve had since the pandemic began, he noted.
Patients with a past history of allergies should be observed for 30 minutes. Be aware that a nurse in Alaska, with no prior history of allergic reaction did have a serious anaphylactic response to the vaccine on December 15.
The U.S. government is shipping the Pfizer-BioNTech vaccine to various states, which will then be in charge of distributing the thermal containers to predesignated locations according to each state’s vaccine rollout plan. Moderna’s vaccine is expected to follow soon.
The CDC has published playbooks and other information to help organizations with the rollout.
Accurate and frequent logging of your refrigerator or freezer temperatures will be among the most important tasks as hospitals and other healthcare providers begin administering the first of two doses of the vaccine.
The vaccines are extremely sensitive to temperature. In addition, they will come in multi-dose vials that must be diluted and then slowly mixed by inverting the bottle back and forth, according to manufacturer’s instructions.
The Pfizer-BioNTech COVID-19 vaccine is being shipped frozen, in thermal containers to keep the first serum approved in the U.S. at ultra-cold temperatures, and then must be kept in those containers or moved to ultra-cold freezers until they are ready for use.
The Moderna vaccine does not need to be kept frozen but is still temperature sensitive.
Both companies are shipping initial storage and administration supplies with each container, as well as detailed instructions on storage and handling, defrosting and ultimately providing the inoculations to patients, said the ECRI experts.
Follow these manufacturer instructions closely, they advised. You do not want to waste any of the vaccine doses.
That includes following the strict, time-honored guidelines for using multi-dose vials with multiple patients, warned Stephanie Uses, PharmD, JD, a patient safety analyst with ECRI. Use one needle on one patient, discard the needle in the appropriate sharps container, use a new needle on the next patient, she said.
Also, be careful to precisely measure the preservative-free sodium chloride the manufacturer provides to dilute the vaccine vials, before slowly inverting the vial back and for the required number of turns, she said.
If you reconstitute the vaccine with too much or too little of the preservative-free mixture you risk giving to little or too much of the vaccine. Too little may render it ineffective and too much may invoke a stronger side effect in the patient. Uses repeated that point several times, noting it was emphasized by the manufacturers.
Both Uses and others noted that while the vaccine is approved by the FDA and has shown to be both effective and safe, there is still not a lot of information about the serum.
While many facilities are rushing to buy ultra-cold freezers, that is not necessary and not even recommended by the CDC, noted Jonathan Gaev, MSE, business line manager-biomed, device evaluations for ECRI.
The shipping containers provided by Pfizer will be sufficient to keep the vaccines frozen as long as the 50-pound supply of dry ice is replaced every five days. Pfizer says it will allow facilities to keep the containers for 30 days.
In addition, each container is equipped with a digital thermometer that will alert Pfizer if temperatures are outside the optimal range, which must stay under at least minus 20 degrees Celsius (or minus 4 degress Fahrenheit.) Pfizer when then alert the facility to deal with the problem.
If you transfer the vaccine to your own freezer, you must keep track of the temperature. In addition, make sure you plan for emergency power outages, warned Gaev.
Moderna vaccines are not shipped frozen, however they must be kept cold, according to manufacturer instructions, said Krishnan.
If you choose to use the shipping containers and replacing the dry ice — frozen carbon dioxide — as required, you will need cryogenic gloves to handle the frozen C02. The dry ice cannot be handled with regular gloves. You will also need to train staff how to handle the ice as well as the vaccine.
Since the gloves are expensive, if you decided to have multiple people using the gloves, they should also each wear a clean pair of exam gloves to maintain infection control within the gloves, she said.
Also remember that as dry ice degrades and warms, it becomes its gaseous version of carbon dioxide, which can cause respiratory problems or even death if the area is not vented adequately, she warned. So, when replacing the dry ice, ensure that the area is either well ventilated or that you open the container and allow it to dissipate before reentering the area.
Even more importantly, when CO2 is trapped in a tightly contained area such as a freezer, when the gas builds it can pressurize and blow, she warned, damaging the freezer and anyone near it.
Also, do not throw it away in your normal waste containers. It must be handled and disposed of with special care, she said.
(Several safety data sheets are available about dry ice online. Here is one from the University of Washington.)
However, you choose to store your vaccines, do not store the Moderna and Pfizer products together. If you have one freezer or refrigerator, at least put them on separate shelves, says the ECRI team.
Also ensure the patient gets a follow up shot from the same manufacturer. The two vaccines are different and not designed to be used together.
And when you educate the patient on side effects, be sure to also give them an appointment for the follow-up. Be prepared to not only send a text or phone call reminder, said Watson. The U.K. medical offices are prepared to go physically find patients for their follow-up shot.
Here is a checklist provided by ECRI to review your vaccine implementation program. Does your program include:
Safe and security handling of vaccines
Cryogenic safety equipment and training
Scheduling and handling, to include, screening and consent documents, verification of recipients ID, post injection observation period, and scheduling of follow-up shot
Nurses and pharmacists, trained on procedures and answering questions
DNV GL Healthcare just announced that CMS is now allowing it to conduct full, deemed, reaccreditation surveys remotely, under certain conditions.
In general, those conditions include that the hospital must be located in an area where the safety threat level from the COVID-19 public health emergency (PHE) is still high or medium, has had few or no infection control deficiencies during its last two surveys, has no condition-level deficiencies nor immediate jeopardy situations, and no outstanding ligature risk problems.
DNV is also required to do another full reaccreditation survey onsite within nine months of the end of the PHE, said the announcement.
Expect the Joint Commission (TJC) and HFAP to follow suit as they work out details with CMS. However, the CEO for the Center for Improvement in Healthcare Quality said his AO was unlikely to change its current survey process.
“We are currently able to meet our survey schedules and obligations by going on-site and see no reason to put our hospitals through a double survey,” said Richard Curtis, RN, MS, HACP.
Since the beginning of summer DNV, like CMS and the other accreditation organizations (AO), has been conducting initial accreditation surveys remotely to broaden hospital capacity and meet the demand for inpatient beds during the COVID-19 pandemic.
CMS later allowed AOs to begin resolving outstanding hospital deficiencies found before the PHE, primarily involving a “desk review” that could also be done remotely.
However, full triennial surveys for reaccreditation still had to be done on site, if they could be done safely.
While TJC and others reported making several hundred on-site surveys by the end of summer, COVID cases began to increase again in many regions.
Discussions were underway earlier this fall between CMS and the AOs on when or how to resume full reaccreditation surveys.
While CMS requires all AOs to do full reaccreditation surveys every three years, DNV’s accreditation model is closely linked to ISO 9000 quality standards and therefore they are on site annually.
DNV’s announcement noted that it has been conducting these annual surveys when possible, if the hospital was not swamped with COVID patients.
“DNV GL currently conducts annual/periodic surveys in accredited facilities remotely using videoconferencing and other secure remote surveying tools and techniques. These surveys have been well-received by our hospitals and have been effective at assessing continued compliance with accreditation and certification requirements,” said the announcement.
“Where non-conformance is found, corrective actions are required following established procedures and timelines. DNV GL will continue to conduct these surveys remotely in 2021 as we continually assess the impact of COVID-19 and the PHE and adhere to CMS guidance.”
The announcement also noted that CMS had allowed initial accreditation surveys to be conducted remotely, and that CMS expected DNV — like the other AOs— to “repeat the full survey on site, with the full complement of surveyors and survey time, when it is safe to travel and survey. Recent procedural guidance from CMS requires this repeat on site accreditation survey to be completed within 9 months of the end of the PHE,” according to DNV.
“These recent changes to CMS procedure for AOs now also permit full, deemed reaccreditation surveys to be conducted remotely, under the following conditions:
The hospital main facility must be located in a county with a medium or high rate of COVID-19 positivity, as published weekly by CMS at https://data.cms.gov/stories/s/q5r5-gjyu. (Although this data is expressed as “Nursing Home Data” CMS considers it uniform and reliable for hospital survey scheduling and planning.) NOTE: In counties categorized with low COVID-19 positivity, (shown in Green in the CMS data table) AO reaccreditation surveys must be performed on site and on schedule, following established AO procedure.
The hospital must have had no non-conformances (NCs) in the Infection Prevention and Control requirements for the 2 most recent accreditation surveys. DNV GL considers the 2 most recent surveys to include any of the following; initial accreditation survey, annual/periodic survey, reaccreditation survey, complaint survey, or follow-up survey.
The hospital must have had no substantiated complaints for 12 months prior to DNV GL scheduling the survey date. CMS requires AOs to consider complaints investigated by any agency with authority for complaint investigations in deemed accredited facilities.
The hospital must have had no Condition-Level NCs or Immediate Jeopardy Situations of any kind in the most recent accreditation survey.
The hospital may not have an open Ligature Risk Extension Request and must have no ligature related NCs in the 2 years prior to DNV GL scheduling the survey date.
The PHE must remain in effect for reaccreditation surveys to be scheduled or conducted remotely
DNV GL is required to repeat the full reaccreditation survey on site, with the full complement of surveyors and survey time, within 9 months of the end of the PHE. DNV GL remains the only AO with an established annual survey process, and we have proposed to CMS that our routine annual/periodic surveys be used to fulfill this requirement, with modifications as necessary to ensure the surveys are considered timely and complete.”
“The CMS requirement that all accreditation surveys must be unannounced remains in effect. For surveys conducted remotely, CMS has offered AOs the flexibility to communicate with their customers in advance of survey to plan the technology platform and logistics of the remote survey. DNV GL will contact the hospital 3 business days in advance of a remote survey to determine and test the best platform and procedure for inviting survey participants.”
“CMS has not made a provision to extend the timeline or conduct follow-up surveys remotely for condition-level non-conformance found during reaccreditation surveys. Required Follow-Up surveys will be conducted according to the existing timeline and procedure,” according to the announcement.
And just like the other AOs, DNV says that for “any survey activity conducted on site, surveyors will follow the organization’s protocols for screening, masking, sanitizing, and distancing, including use of videoconference technology to address restrictions on staff or access to higher risk areas within the facility. This can also include minimizing our cumulative time on site to complete a follow-up survey activity while completing the essential function of verifying compliance.”
DNV asks clients to direct question about the new survey processes to its drop box: DNVclientdropbox@dnvgl.com
Refer to your policy on influenza vaccinations as you consider whether to require employees to get the COVID-19 vaccine when it becomes available.
Expect to deal with many of the same exemptions—such as health concerns or religious reasons—to mandatory COVID shots as you do with a mandatory flu vaccination requirement.
The Equal Employment Commission (EEOC) updated its pandemic preparedness FAQ at the start of the public health emergency (PHE) in March.
In answer to the question, “May an employer covered by the ADA [Americans with Disabilities Act] and Title VII of the Civil Rights Act of 1964 compel all of its employees to take the influenza vaccine regardless of their medical conditions or their religious beliefs during a pandemic?”
Quick answer: No.
“An employee may be entitled to an exemption from a mandatory vaccination requirement based on an ADA disability that prevents him from taking the influenza vaccine. This would be a reasonable accommodation barring undue hardship (significant difficulty or expense). Similarly, under Title VII of the Civil Rights Act of 1964, once an employer receives notice that an employee’s sincerely held religious belief, practice, or observance prevents him from taking the influenza vaccine, the employer must provide a reasonable accommodation unless it would pose an undue hardship as defined by Title VII (“more than de minimis cost” to the operation of the employer’s business, which is a lower standard than under the ADA),” states the FAQ, last updated on March 21.
“Generally, ADA-covered employers should consider simply encouraging employees to get the influenza vaccine rather than requiring them to take it.” As a footnote to that answer, the EEOC notes that at the time of the update, there was no vaccine available for COVID-19.
Now that there is a vaccine, employers should have a thorough discussion before making it mandatory, says Jennifer Aaron Hataway, an attorney with Butler Snow LLP, writing for HRLaws.com, a brand under BLR, the parent company to Simplify Compliance.
“Begin to consider how you’ll address the COVID-19 vaccine and find ways to give employees a voice in the decision making process,” advises Hataway.
“In some ways, whether you should implement a mandatory COVID-19 policy is a more difficult question than whether you could do so,” Hataway notes. “Employers imposing the requirement should expect to receive a significant number of disability and religious accommodation requests from employees. Be ready for the administrative burden and stay up to date on not only the disability and religious accommodation laws but also the ever-changing guidance from public health authorities.”
“Lawfully processing employees’ vaccination exemption requests, particularly those based on religious beliefs, will require well-trained HR pros and potentially the assistance of in-house or outside legal counsel. You’ll be required to engage in the interactive process and, if necessary, determine reasonable accommodations such as minimizing employee interactions, requiring masks, offering separate offices, or allowing remote work,” adds Hataway.
Local and state jurisdictions having authority may also weigh in on whether the vaccines can be required.
There is a lot still to be decided about the COVID-19 vaccines, including when and where they will be dispensed and who will get them first. CDC has recommended that healthcare workers and residents of long-term care facilities be among the first recipients.
However, informal surveys show that many healthcare providers are leaning toward not making the vaccine mandatory while others are undecided and awaiting more information.
Currently, under The Joint Commission’s (TJC) Infection Control standard IC.02.04.01, hospitals are required to offer flu vaccines to licensed independent practitioners and staff, but are not required to make annual flu shots mandatory.
The hospital is required to track why employees decline to get the vaccination, as well as gathering other information.
You have until December 24 to deliver your gift of information to HHS through its Innovation RFI Response Portal at the National Institutes of Health Office of Extramural Research.
Hundreds, if not thousands, of clinicians, facility engineers, healthcare systems and other care providers have been forced to get creative in order to deal with the rapidly evolving COVID-19 pandemic. And the government wants to hear your success stories.
CMS and the Department of Health and Human Services (HHS) has published a request for information on “Effective and Innovative Approaches/Best Practices in Health Care in Response to the COVID-19 Pandemic.”
According to the request, published in the Federal Register November 24, HHS “seeks to gain a comprehensive understanding of the impact of changes adopted by health care systems and health care providers in response to the COVID-19 pandemic. Many healthcare systems and clinicians have rapidly reengineered their policies and programs to improve access, safety, quality, outcomes including mortality and morbidity, cost, and value for both COVID-19 and non-COVID-19 related medical conditions. HHS plans to identify and learn from effective innovative approaches and best practices implemented by non-HHS organizations in order to inform HHS priorities and programs.”
The 15-page request has a lengthy background and description of the information it seeks, with an emphasis on healthcare innovations.
Said HHS: “The main purpose of this Request for Information (RFI) is for HHS to gather information on effective innovative approaches and best practices in health care in response to the COVID19 pandemic by non-HHS health care systems and providers. The information provided will help inform and guide the HHS response to build a healthy and resilient nation.”
You have until December 24 to deliver your gift of information to HHS through its Innovation RFI Response Portal at the National Institutes of Health Office of Extramural Research.
The online form has a series of questions that will guide you through your submission.
Anything received after midnight on Christmas Eve will not be accepted. Please note that’s Eastern time.
And when you’re done, send a note to us here at the Accreditation & Quality Compliance Center telling us about the wonderful things you’ve done. We’d love to talk to you and share with your colleagues.
You can email Inside Accreditation & Quality editor A.J. Plunkett at aplunkett@decisionhealth.com. Be sure to put INNOVATION IDEAS in the subject line.
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