COVID-19 time line, February 2021: The distribution of COVID-19 vaccines was in its early stages.
Fast forward to today: More than 200 million Americans are fully vaccinated against COVID-19, which has gone a long way toward helping healthcare organizations safely resume normal operations and begin to recover financially. However, that number accounts for only 65% of the total U.S. population. And with rapidly decreasing emphasis on social distancing and masking, health systems wisely continue to exercise caution when it comes to hospital visitor vaccine policies and vendor credentialing and vaccines.
Here’s why and how healthcare leaders are proceeding to ensure safety and compliance for all.
Costs of noncompliance with current vaccine mandates
The Centers for Medicare & Medicaid Services (CMS) has begun to enforce vaccine mandates, and there are several important deadlines for healthcare organizations, outlined in an FAQ (i.e., "External FAQ: CMS Omnibus COVID-19 Health Care Staff Vaccination Interim Final Rule") initially issued by CMS in November 2021 and updated in January 2022.
For providers and suppliers subject to CMS Conditions of Participation, there are three groupings of deadlines based on location:
- Group 1: California, Colorado, Connecticut, Delaware, District of Columbia, Florida, Hawaii, Illinois, Maine, Maryland, Massachusetts, Michigan, Minnesota, Nevada, New Jersey, New Mexico, New York, North Carolina, Oregon, Pennsylvania, Rhode Island, Tennessee, Vermont, Virginia, Washington and Wisconsin
- Group 2: 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
- (Group 3): Texas
Phase 1 Deadline
Phase 2 Deadline
Jan. 27, 2022
Feb. 28, 2022
Feb. 14, 2022
March 15, 2022
Feb. 22, 2022
March 21, 2022
According to public affairs group McGuire Woods Consulting, "Facilities without 100% staff compliance by the Phase 1 deadline face written notice of noncompliance by surveyors. However, CMS has instructed surveyors that if a facility has achieved 80% vaccination compliance and has a plan to achieve a 100% staff vaccination rate within 60 days, the facility should not be subject to additional enforcement action."
The penalties for healthcare organizations that fail to comply include:
- Denial of CMS payments or termination of CMS contract(s)
- Development and leveling of a CMS Corrective Action Plan
- Civil monetary penalties
Determine the vaccination needs for vendors, employees, and visitors
Vendor representatives and staff: Most states leave vaccine requirements up to individual facilities and organizations, whether for COVID-19 or for a host of other diseases. But as a general rule, healthcare employees and healthcare vendors should be vaccinated against the following diseases:
- Hepatitis B
- Measles, Mumps, and Rubella (MMR)
- Tetanus, Diphtheria, and Pertussis (TDAP)
Visitors: When it comes to COVID-19 vaccinations for visitors, your organization likely will need to be more flexible. Vaccine hesitancy has increased significantly in recent years; in fact, the World Health Organization recently listed it as one of the 10 biggest threats to global health.
To minimize the potential for confrontations between visitors and staff, healthcare leaders should focus less on proof of vaccination for COVID-19 and more on effective visitor management. This could include educating visitors on the risks of COVID-19, establishing designated visiting areas for unvaccinated guests, and ongoing monitoring of COVID-19 positivity rates in the facility and surrounding areas to adjust visitation guidelines when necessary.
Build stronger, safer vaccination policies
In the first two years of the pandemic, one of the biggest priorities for healthcare facilities was to adjust supplier- and vendor-management policies to address the unique challenges of COVID-19. While most healthcare organizations had well-established vendor policies, few anticipated the drawn-out timeline of barred or restricted access that COVID-19 presented. Now that vaccines are widely available, the focus is shifting toward the following initiatives to build stronger and more robust vaccination policies for vendors, staff, and visitors:
Keep everyone informed
Before vaccine distribution began, vendors needed to be informed about any COVID-19 developments, because at any moment a surge in new cases could have required healthcare organizations to restrict vendor representative access to their facilities. It was a crucial part of vendor management, but it meant supply chain managers and procurement departments had to remain in constant contact with vendors—which required a significant investment of time and effort on both ends.
As our collective vaccination rate for COVID-19 rises, the risk of healthcare organizations having to shut down or limit access to their facilities decreases. As a result, supply chain managers can spend less time providing updates and sending out new guidelines. But that doesn’t mean health system leaders should abandon the vendor-management infrastructure they built or strengthened during the early days of this pandemic. Instead, they must consider adapting that infrastructure to meet ongoing communication needs for vendors and third-party suppliers to readily handle the day-to-day access management of their facilities—as well as in future crisis, disaster, or emergency situations.
Ensure credentialing standards cover on-site and virtual vendors
Many healthcare supply chain businesses have pivoted to conduct their business operations primarily in a virtual environment. Therefore, it’s crucial that your organization’s credentialing standards can be applied to both on-site and virtual vendors. Fortunately, this should largely be a matter of updating your credentialing standards to include virtual vendors and rolling out those changes across your organization.
Facility access management technology is more than electronic badges for registration, mobile access, and authorized contactless entry. It ensures vendors and suppliers meet organizational requirements, undergo training, and review and attest to mandatory policies regardless of how they “check in,” schedule appointments, and manage their accounts.
Standardize vaccine requirements across your organization
Statewide COVID-19 vaccine requirements are rare, and where they do exist they vary according to the state and healthcare organization type. This applies not only to healthcare workers, but to vendors and visitors as well. For example, in Massachusetts, the COVID-19 vaccine is required only for healthcare workers and contractors in skilled nursing facilities, rest homes, assisted living facilities, and hospice programs, as well as workers who provide in-home healthcare services. (There are medical and religious exemptions.)
In New York, however, all healthcare employees are required to get a COVID-19 vaccine unless a physician or nurse practitioner provides written certification that the individual has a pre-existing health condition (such as Guillain-Barre Syndrome), with no religious exemptions. Even though most states do not have uniform guidelines for COVID-19 vaccines, healthcare organizations can—and should—establish their own uniform vaccination requirements for employees, vendors, and visitors across all facilities within the organization.
Standardizing vaccine requirements is especially important for health systems that operate in multiple states or regions, particularly if the organization uses the same vendors to service multiple locations. As noted, uniform vaccine requirements will help simplify the vendor credentialing process for your organization, but above all, it will help keep your staff and patients safe. Software solutions such as Survey Manager, part of symplr Compliance can also help healthcare leaders securely track vaccination status of employees to document evidence that your organization remains compliant with state and local guidelines.
For obvious reasons, healthcare facilities’ vaccine procedures and requirements will likely be more strict for vendors and employees than for visitors, but if yours doesn’t require visitors to be vaccinated, this could pose an increased risk to staff and patients. Therefore, it is imperative to implement or update visitor management guidelines to ensure that if a visitor is unvaccinated, they still adhere to the disease-prevention guidelines your organization likely implemented in the early days of the pandemic.
Strongly reinforce vaccination policies
Strong vaccination policies and procedures that are strictly enforced can make the difference between operating safely and efficiently, and constantly being forced to navigate the challenges of COVID-19. A weak vaccination policy introduces the potential for patient safety issues, workforce management workflow challenges, and problems with vendor management—all of which jeopardize compliance and waste valuable resources.
One tool that can help healthcare leaders implement strong vaccination policies is digital vaccine credentialing. Many states have rolled out their own digital vaccine credentialing systems, which reduce the burden on vendors and suppliers who often have to request their vaccination records as part of their credentialing requests. In most cases, these vaccine credentialing systems solely address the COVID-19 vaccine. However, it is likely that your existing vendors have already submitted other immunization records, so the digital credentialing system should work to provide that one key piece of information about the vendors you currently work with.
Last year, many healthcare leaders had to spend a significant amount of time overhauling their vendor management policies in a short time frame. With all of that hard work behind them, healthcare leaders won’t need to do it again this year—but they will need to update revamped systems to account for COVID-19 vaccinations. By doing so, they can ensure their healthcare organizations remain flexible and adaptable. symplr’s software solutions can help simplify the process and track vendor credentialing and COVID vaccinations.