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CMS Issues New QSO on Staff Vaccination and How Surveyors Will Survey Against It

On June 14th, the Centers for Medicare and Medicaid Services (CMS) issued memorandum QSO 22-17-ALL updating how State Survey Agencies (SAs) will survey for compliance with COVID-19 staff vaccination. The QSO updates previously issued federal guidance that stated that all surveys would ensure compliance with staff vaccination. As of the date of issuance of QSO 22-17-ALL, SAs are only required to complete surveillance for compliance on initial surveys, recertification surveys, and complaint surveys alleging a specific complaint related to staff compliance with COVID-19 vaccination.

It is important to note that SAs do retain the authority to survey for compliance on any survey if they choose to, and the New York State Department of Health (DOH) does often go beyond the requirements in the guidance issued by the federal government.

Contact: Mark Kepner-Clough, mkepner-clough@leadingageny.org, 518-728-2365