CMS Issues Memo Outlining Surveyor Vaccination Expectations

Last week, the Centers for Medicare and Medicaid Services (CMS) issued memorandum QSO-22-10-ALL outlining its expectations regarding vaccination of surveyors.

Surveyors performing federal oversight, including state survey agencies (SSAs) and accrediting organizations (AOs), are expected to be vaccinated for COVID-19. Similar to certified providers, SSAs/AOs must also have a process for requesting and evaluating exemptions from COVID-19 vaccination based on medical contraindications or religious objections. Surveyors who are neither vaccinated nor exempted from vaccination should not be part of on-site survey teams. Unvaccinated surveyors may participate in off-site records reviews, survey preparation, etc. While surveyors who have been granted exemption will be permitted to join on-site survey teams, these individuals will be subject to additional precautions as determined by the state such as mandatory testing, reassignment, or work modifications. CMS states clearly that compliance with this expectation is the role of the SSA or AO. As such, providers may not request proof of vaccination or exemption as a condition of entry. Questions or concerns related to surveyor vaccination should be referred to the SSA or AO. The memo and expectations are effective 30 days from Jan. 25, 2022.

LeadingAge NY encourages all nursing home members to read the QSO in its entirety and reach out to Amy Nelson with any questions.

Contact: Amy Nelson, anelson@leadingageny.org, 518-867-8383 ext. 146