Practice Management

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  • 1.  COVID Vaccine

    Posted 09-09-2021 16:55
    Good afternoon:

    Here is information just released from CMS regarding a pending requirement for all health care workers to be vaccinated.  

    Biden-Harris Administration to Expand Vaccination Requirements for Health Care Settings

     New action will protect patients of the 50,000 providers and over 17 million health care workers in Medicare and Medicaid certified facilities

    The Biden-Harris Administration will require COVID-19 vaccination of staff within all Medicare and Medicaid-certified facilities to protect both them and patients from the virus and its more contagious Delta variant.  Facilities across the country should make efforts now to get health care staff vaccinated to make sure they are in compliance when the rule takes effect.

    The Centers for Medicare & Medicaid Services (CMS), in collaboration with the Centers for Disease Control and Prevention (CDC), announced today that emergency regulations requiring vaccinations for nursing home workers will be expanded to include hospitals, dialysis facilities, ambulatory surgical settings, and home health agencies, among others, as a condition for participating in the Medicare and Medicaid programs. The decision was based on the continued and growing spread of the virus in health care settings, especially in parts of the U.S. with higher incidence of COVID-19. 

    "There is no higher priority for us than patient health and safety. As the Delta variant strengthens, the Biden-Harris Administration is committed to doing everything we can to keep patients, and those who care for them, safe," said U.S. Department of Health and Human Services (HHS) Secretary Xavier Becerra. "There is no question that staff, across any health care setting, who remain unvaccinated pose both direct and indirect threats to patient safety and population health. Ensuring safety and access to all patients, regardless of their entry point into the health care system, is essential."

    Nursing homes with an overall staff vaccination rate of 75% or lower experience higher rates of preventable COVID infection. In CMS's review of available data, the agency is seeing lower staff vaccination rates among hospital and End Stage Renal Disease (ESRD) facilities. To combat this issue, CMS is using its authority to establish vaccine requirements for all providers and suppliers that participate in the Medicare and Medicaid programs. Vaccinations have proven to reduce the risk of severe illness and death from COVID-19 and are effective against the Delta variant.  CMS will continue to work closely with all Medicare and Medicaid certified facilities to ensure these new requirements are met.

    "We know that those working in health care want to do what is best for their patients in order to keep them safe," said CMS Administrator Chiquita Brooks-LaSure.  "As the Delta variant continues to spread, we know the best defense against it lies with the COVID-19 vaccine. Data show that the higher the level of vaccination rates among providers and staff, the lower the infection rate is among patients who are dependent upon them for care. Now is the time to act. I'm urging everyone, but especially those fighting this virus on the front lines, to get vaccinated and protect themselves, their families, and their patients from COVID-19."

    CMS is developing an Interim Final Rule with Comment Period that will be issued in October.  CMS expects certified Medicare and Medicaid facilities to act in the best interest of patients and staff by complying with new COVID-19 vaccination requirements.  Health care workers employed in these facilities who are not currently vaccinated are urged to begin the process immediately. Facilities are urged to use all available resources to support employee vaccinations, including employee education and clinics, as they work to meet new federal requirements.

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    Robert Still FRBMA
    Executive Director
    Radiology Business Management Association (RBMA)
    Fairfax VA
    (703) 621-3363
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  • 2.  RE: COVID Vaccine

    Posted 09-10-2021 05:51

    "CMS is developing an Interim Final Rule with Comment Period that will be issued in October.  CMS expects certified Medicare and Medicaid facilities to act in the best interest of patients and staff by complying with new COVID-19 vaccination requirements.  Health care workers employed in these facilities who are not currently vaccinated are urged to begin the process immediately. Facilities are urged to use all available resources to support employee vaccinations, including employee education and clinics, as they work to meet new federal requirements."

     

    Enforcement for those hospitals that resist compliance could be time consuming.  As noted by one of Paul Pitts' and my partners:

     

    "October for a rulemaking.  Then surveys and citations.  Opportunities for Plans of Correction.   Plus appeals.  Substantial compliance is the OBRA standard for SNFs.  Is that the standard for other sites of service?  Bottom line is that this pandemic will be over before they can effectively implement this requirement where providers are unwilling to do so."

     

    Thomas W. Greeson

    703.517.0495 (cell)

    tgreeson@reedsmith.com

    Pronouns: He/Him/His

     

    Reed Smith LLP

    7900 Tysons One Place

    Suite 500

    McLean, Virginia 22102-5979

    Office Telephone: 703 641 4242

    Facsimile:   703 641 4340

     

     

     

     

     






  • 3.  RE: COVID Vaccine

    Posted 09-13-2021 12:55
    I just came back from a "news blind" vacation and saw the new mandates. I have several questions that I am hoping the RBMA community can help with:

    We have not made vaccinations a requirement for our staff as of yet. Not taking a political stance, rather we did not feel the current mandate required outpatient imaging centers to do so. Now that all practices that receive reimbursement from CMS are required to do so, we most certainly will comply. 

    Has CMS/ Federal government given a deadline for vaccinations? (ie: all employees must show proof of vaccination by 10/1)

    Are religious/ health issues still an acceptable excuse?

    Will Biden's order be challenged in court?

    If so, do the legal challenges mean the mandate is not enforceable while the case is being heard?

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    Lee Johnson MBA, RT(R), MR
    Practice Administrator
    Adirondack Radiology Associates, PC
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  • 4.  RE: COVID Vaccine

    Posted 09-13-2021 13:09
    I am curious on this as everything I have read reference "Facilities" and as a private practice imaging center we do not fall under the "facility" classification.  I know they are in the process of writing the rule but I am curious if others have the same take that a private practice will not have to comply?

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    John Griffith RT(R)(MR)(CT)
    Administrator
    Dakota Radiology
    Rapid City SD
    (605) 342-2852
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  • 5.  RE: COVID Vaccine

    Posted 09-13-2021 13:09

    Lee,

     

    These are good questions.  Note that CMS and other government agencies will be issuing Interim Final Rules regarding the vaccination and public health emergency orders so stand by for answers to your questions.  Also note that while some believe these are "political" decisions they are really decisions about the best course of action for health care providers to take to protect both patients and staff.  My personal opinion is that reassuring patients of a COVID safe environment is something that would be a good marketing tool for all radiology organizations. 

     

    Sent from Mail for Windows

     






  • 6.  RE: COVID Vaccine

    Posted 09-13-2021 13:09

    IMHO...

     

    CMS has not issued the final rule so we are all still waiting to see what it says and what time frame it lists. Also OSHA and the dept of labor haven't issued the final rule regarding employers with 100 plus employees.

     

    Religious exemptions are still valid but also up to the employers to decide if they accept them. I was told by our legal reps that if the exemption causes us undue financial or logistics hardships we can refuse to accept or give the exemptions. I saw where United Airlines (I think it was United) stated any employee who files for a medical or religious exemption and are approved for that exemption would be placed on unpaid PTO until the pandemic was lifted or the number of infected was drastically reduced.

     

    I am sure there will be multiple legal challenges to the mandates.

     

    I don't know the answer to the last question as we haven't seen the final rule so our legal reps haven't advises us on matter.

     

    RESPECTFULLY, 

     

    Rick D Gladish, RCC, CPC

    MD Revenue Management, LLC

    111 Troy St STE F

    Tupelo, MS 38804

    ph 662-620-7102 fax 662-620-7106

    email: rick@mdrm.us

    website: www.mdrm.us

     

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  • 7.  RE: COVID Vaccine

    Posted 09-13-2021 14:59
    My interpretation, and what I've read elsewhere, is that the mandate tied to Medicare and Medicaid reimbursement only applies to facilities, and it doesn't apply to physician practices.  I suspect IDTF's would be considered facilities, but I haven't seen anything specific on that.

    If you have more than 100 employees, then the general OSHA mandate may apply.

    Undoubtedly the whole thing will end up in court, but whether the plaintiffs can get an injunction against enforcement is anyone's guess.  I don't think there can be any court proceedings until an actual rule is published.


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    David Smith FACMPE
    Executive Director
    United Imaging Consultants
    Mission KS
    (785) 393-8387
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  • 8.  RE: COVID Vaccine

    Posted 09-13-2021 15:52

    Thanks Sharon...

     



    Mark Leggett, Practice Administrator
    Millennium Medical Imaging, PC

    Cell 518.275.7126 Fax 518.734.0134 | www.mmipc.com
    188 Church Street, Saratoga Springs NY 12866

     


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