On November 5, 2021, the Centers for Medicare and Medicaid Services (CMS) published an interim final rule that requires vaccinations for certain health care workers. The rule is limited to only those entities who are surveyed by CMS and have Conditions of Participation, Conditions for Coverage, or Requirements for Participation in the Medicare and Medicaid programs. Our health care team recently summarized the rule, and is continuing to follow developments in this area.

In addition, our labor and employment team also provided a similar overview of the new Occupational Safety and Health Administration (OHSA) final rule. OHSA has issued its COVID-19 Emergency Temporary Standard (ETS) for private employers, which goes into effect on December 5, 2021, though as of this posting, the U.S. Court of Appeals for the 5th Circuit temporarily blocked the mandate while the court reviews it.