IMPORTANT UPDATE: January 14, 2022

On Thursday, January 13, 2022, the U.S. Supreme Court ruled in favor of the CMS COVID-19 Healthcare Staff Vaccination Requirement. With this ruling, Montana healthcare providers are again subject to the CMS Interim Final Rule issued on Nov. 4, 2021.

CMS issued guidance on January 14, 2022 to clarify standards, enforcement deadlines and measures for states (including Montana) where the implementation of the requirement was paused by injunctions placed by lower federal courts. Now that the stay on this case has been lifted by the Supreme Court, Montana healthcare providers that provide care to Medicare and Medicaid patients are required to demonstrate that all healthcare staff are fully-vaccinated against COVID-19.

The 1/14/22 guidance requires that facilities demonstrate 100% vaccination rate by February 14, 2022. The guidance provides specific thresholds for remaining in compliance at 30-day (February 14, 2022), 60-day (March 15, 2022), and 90-day (April 14, 2022) marks following the issuance of the Jan. 14, 2022 memorandum.

Click here to access 1/14/22 CMS COVID-19 Vaccine Requirement guidance.

Click here to access 1/27/22 DPHHS Guidance Related to Federal Vaccine Mandate. 

See below for additional resources and templates provided by MHA in response to the original guidance issued in Nov. 2021. While the deadlines have shifted, the templates are in compliance with current federal and state requirements.

Special Message from MHA President and CEO Rich Rasmussen and Attorney Dan Auerbach
January 14, 2022



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