DNV Updates Requirements on Medical Exemptions for COVID-19 Vaccine

By A.J. Plunkett

Check any medical exemptions from the COVID-19 vaccination that your facility approved before the CMS requirements for hospitals went into effect, says DNV Healthcare officials.

“Granted medical exemptions that do not meet the requirements of the rule (i.e., do not state the specific vaccine(s) contraindicated and the recognized clinical reason for the contraindication with a statement recommending exemption), including those granted prior to the effective date of the rule, must be updated to include any missing elements consistent with the requirements of the rule,” according to a DNV advisory published May 4.

“Any deficient hospital policies must also be updated to reflect all necessary elements as outlined in the rule to be considered compliant,” said the advisory.

“Currently, all states are in Phase 3 (full enforcement) of the rule, requiring 100% of staff to be vaccinated (completion of a primary vaccination series for COVID-19 to include administration of a single-dose vaccine, or the administration of all required doses of a multi-dose vaccine, or at least one dose for new staff), have a pending (with deadline and contingency plan) or granted exemption, or are identified as having a temporary delay, as recommended by CDC, due to clinical precautions and considerations,” said the advisory.

DNV said it issued the advisory after receiving clarification from CMS on the requirements.

The advisory also notes that additional precautions are required for staff who are not yet fully vaccinated.

Examples may include, according to the advisory:

• Reassignment of staff to nonpatient care areas to duties that can be performed remotely (e.g., telework), or to duties which limit exposure to those most at risk (e.g., assign to patients who are not immunocompromised, unvaccinated)
• Following additional, CDC-recommended precautions
• Weekly testing, regardless of whether the facility or service site is located in a county with low to moderate community transmission, in addition to following CDC recommendations for testing unvaccinated in facilities located in counties with substantial to high community transmission
• Additional source control (i.e., NIOSH-approved N95 or equivalent or higher-level respirator regardless of whether they are providing direct care to or otherwise interacting with patients)

“This requirement is not explicit and does not specify which actions must be taken. The examples given in the CMS guidance are not all inclusive and represent actions that can be implemented,” according to the advisory. “Facilities may also consult with their local health departments to identify other actions that can potentially reduce the risk of COVID-19 transmission from unvaccinated staff.”

The four-page advisory also offers information about source control, signage, and screening.

For the full advisory, which also includes links to information from CMS, go here.

A.J. Plunkett is editor of Inside Accreditation & Quality, a Simplify Compliance publication.