By: Winona L. Thomas, BS, HCS

Since the first onset of COVID-19 vaccination mandate in May and June 2021, the VAX mandate has been an abrupt disruption in the lives of millions of Health Care workers.


The Biden-Harris Administration has mandated COVID-19 vaccinations for clinical and non-clinical healthcare workers employed by a certified Medicare or Medicaid-funded facility.

What does this mean for the more than 17 million workers employed by healthcare facilities?

According to the Centers for Medicare and Medicaid Services (CMS):
“Facilities covered by this regulation must establish a policy ensuring all eligible staff has received the first dose of a two-dose COVID-19 vaccine or a one-dose COVID-19 vaccine prior to providing any care, treatment, or other services by December 6, 2021. All eligible staff must have received the necessary shots to be fully vaccinated – either two doses of Pfizer or Moderna or one dose of Johnson & Johnson – by January 4, 2022. The regulation also provides for exemptions based on recognized medical conditions or religious beliefs, observances, or practices. Facilities must develop a similar process or plan for permitting exemptions in alignment with federal law.”

(“Biden-Harris Administration Issues Emergency Regulation Requiring COVID-19 Vaccination for Health Care Workers,” 2021, November 4,

What are Certified Medicare and Medicaid funded facilities?

According to the CMS a certified facility is one that has met the requirements to receive Medicare or Medicaid payments. This mandate would be adhered to by any facility that is regulated under the Medicare health and safety standards known as Conditions of Participations (CoPs) or Conditions for Coverage (CfCs). For further information regarding CoPs and CfCs, please visit the CMS Omnibus Covid-19 final rule at

These requirements apply to:

  • Ambulatory Surgical Centers
  • Hospices
  • Programs of All-Inclusive Care for the Elderly
  • Hospitals
  • Long Term Care facilities
  • Psychiatric Residential Treatment Facilities
  • Intermediate Care Facilities for Individuals with Intellectual Disabilities
  • Home Health Agencies
  • Comprehensive Outpatient Rehabilitation Facilities
  • Critical Access Hospitals
  • Clinics (rehabilitation agencies, and public health agencies as providers of outpatient physical therapy and speech-language pathology services)
  • Community Mental Health Centers
  • Home Infusion Therapy suppliers
  • Rural Health Clinics/Federally Qualified Health Centers
  • End-Stage Renal Disease Facilities

As we hear about COVID cases increasingly on the rise in the world with no good news of the pandemic being eradicated in the near future, healthcare facilities are acting upon what they believe would be the best strategy for the health and safety of patients, staff, and clients within the health care system.

For more information on the Certification Process for Medicare and Medicaid, please visit

Winona L. Thomas, BS, HCS is a Reimbursement Specialist at MedCycle Solutions, which provides Revenue Cycle Management, Credentialing, Outsourced Coding and Consulting Services to a number of healthcare providers in a variety of specialties. To find out more about MedCycle Solutions services, please visit