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CMS Vaccine Mandate: Deadlines now set for all states

Medicare and Medicaid providers in the 24 states involved in the court challenges at the center of the Supreme Court decision on January 13 now have fresh deadlines to implement their COVID-19 vaccine mandates. And CMS issued the last deadlines, for Texas providers, on Jan. 20.

In a message to surveyors Jan. 14, 2022, CMS issued new 30- and 60-day deadlines for compliance for agencies in Alabama, Alaska, Arizona, Arkansas, Georgia, Idaho, Indiana, Iowa, Kansas, Kentucky, Louisiana, Mississippi, Missouri, Montana, Nebraska, New Hampshire, North Dakota, Ohio, Oklahoma, South Carolina, South Dakota, Utah, West Virginia and Wyoming.

Based on that timeline:

  • Phase 1 of the mandate, including policies around mandate implementation and a first vaccine dose for all employees, is due by Monday, Feb. 14, 2022.
  • Phase 2 of the mandate, when all eligible employees should be fully vaccinated with a second dose of a vaccine, is due by Tuesday, March 15, 2022.

On Jan. 20, 2022, CMS released deadlines for Texas, which had been the subject of a separate injunction:

  • Phase 1: Feb. 22, 2022.
  • Phase 2: March 21, 2022.

Providers in all other states are still subject to the deadlines announced in late December:

  • Phase 1: Jan. 27, 2022.
  • Phase 2: Feb. 28, 2022.