Dear Members,

Thank you for all that you continue to do especially during these very challenging and, occasionally, overwhelming times. Your commitment to our society’s most vulnerable citizens is heroic, indeed, amazing. Thank you all very, very much!

Since December 23^rd, we all have received a lot of information from federal regulatory agencies as well as the Wisconsin Department of Health Services. Much of this material is quite complex and some of it is confusing and/or conflicting. The purpose of this Member Memo is an attempt to bring some focus and clarity. 

On Friday, December 23, 2021, The Wisconsin Department of Health Services (DHS) issued a Bureau of Communicable Diseases Information Update. Read the document HERE.

This document will direct you to several other CDC documents, including the Interim Guidance for Managing Healthcare Personnel with SARS-CoV-2 Infection or Exposure to SARs-CoV-2 and the updated Strategies to Mitigate Healthcare Personnel Staffing-Shortages.

The following chart is the best way to determine how to identify vaccinated vs unvaccinated employee restrictions based on conventional, contingency and crisis staffing levels:

Guidance for the Interim Final Rule - Medicare and Medicaid Programs: Omnibus COVID-19 Health Care Staff Vaccination. This document does apply to Wisconsin which was not included in the original injunction for other states.

In addition, on December 28, 2021, CMS issued QSO-22-07-ALL that is now effective in the State of Wisconsin. The document sets forth the new timelines for the implementation of the vaccine mandate. It is effective 30 days after issuance of the memorandum which would be 1/27/22 to ensure the first dose of the vaccine is given and 60 days for the completion of the 2 dose vaccination. Although the Supreme Court is scheduled to hear this case on January 7th, CMS has chosen to issue the guidance.

Our urgent request to you: You need to make sure that your systems are in place to ensure all staff are vaccinated within the timeline. In addition, Attachment A of the memo includes regulatory implications of the rule, with identification of the Scope/Severity of deficiencies for LTC and SNF Facilities. An important detail is that if your staff vaccination rate is below 60% you are at risk for an L level Immediate Jeopardy citation. Please thoroughly review this document.

To help members in the impacted states like Wisconsin comply with the vaccine mandate, AHCA/NCAL has updated its template policies and procedures (Microsoft Word download), available on the COVID-19 website under the Vaccines section. Additional resources to help encourage vaccine uptake, including new handouts on boosters, can also be found on the #getvaccinated website.

Finally, AHCA/NCAL has scheduled a webinar for Thursday, January 6, 2022 at 2:00 pm CST to review OSHA's vaccine and testing mandate. To register for the webinar, please click HERE.

Please do not hesitate to contact Director of Government Relations and Regulatory Affairs Jim Stoa, Director of Quality Advancement and Education Pat Boyer, or CEO Rick Abrams if you have any questions or if we can assist you in any way. Once again, thank you for all that you and your colleagues continue to do. All the best for a happy, safe and prosperous 2022!