Hello CSW members,
 
The pandemic continues to be a challenging issue creating what seems to be a never ending chaos of confusion.
 
Yesterday was no exception.  President Biden’s speech contained many action steps he wants to take related to the pandemic included the increased pressure for mandatory vaccinations.
 
The key headline that we believe will be of concern for our members involves the threat of Medicare payments reductions to non-vaccinated healthcare providers.   
 
After legal review of the CMS document, we do not believe that chiropractic offices will be included in the terminology of “facilities,” but we will continue to monitor as this moves forward.
 
Please know that there are processes that all Federal agencies need to follow to implement changes in rules or regulations.  The pandemic emergency declaration does allow for some of the processes to be expedited, but there still are rules that have to be followed.
 
The CSW is monitoring all aspects of this issue and of course the issues of your patients, many of whom work in businesses of over 100 employees.  Just as we did with the start of the pandemic, as qualified data is released, we will provide it to our members to help them navigate this very difficult situation.
 
We believe that they plan on using a very obscure OSHA regulation to attempt to implement the employers of 100 or more employees.  Our initial legal review indicates that this attempt by the White House is not strong and will have multiple legal challenges against it.
 
The efforts by CMS will be more directly associated with any payments to your clinics from Medicare and potentially Medicaid.  Our initial review of the CMS release indicates that their initial focus is on specific healthcare facilities and that chiropractic offices are not named in the document and the only listed category that a chiropractic office would only fall under is the “other facilities” category.    
 
After legal review of the CMS document, we do not believe that chiropractic offices will be included in the terminology of “facilities,” but will continue to monitor as this moves forward.
 
We expect this process to take a few weeks at the earliest to move forward and we will continue to monitor and provide the necessary data for each member to be informed of the effects these actions may have on your individual clinics.