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03/01/2022

You Asked... We Answered 3/1/22

You Asked: 

Regarding our hospice inpatient unit (IPU), we have patients being transported to and from our IPU via ambulance. These are not emergency transports. I was initially told that we did not need to ensure compliance of the ambulance staff having COVID-19 vaccines as they fell under emergency services, but just this morning was told that we should have verification of the compliance of each ambulance staff member entering our hospice inpatient unit. What is your take on this?

We Answered

CMS clarified in a stakeholder meeting recently that if the ambulance transport is for emergency reasons (911 was called), then you as a facility are not responsible for the EMS to be vaccinated. But, if you have a contract with an ambulance service that does non-emergent transports for your patients, then those ambulance staff (EMS) do fall under the mandate as a contracted vendor. As a hospice, you are responsible for your contracted vendors, so therefore the ambulance staff need to be vaccinated or have an exemption based on your policy. Please see the CMS Q&A below:

Question: Are emergency medical services (EMS) workers subject to the COVID-19 vaccination requirements?

Answer: EMS providers are not regulated by CMS health and safety standards; therefore, they are not directly subject to these requirements. Some EMS providers may be subject to the vaccination requirements by virtue of their professional relationship with a health care entity that is regulated by CMS. For example, a hospital may contract with EMS providers and therefore these staff would be included in the requirement. Additionally, an EMS provider may also provide non-emergency transportation for Long Term Care facility residents under contract. In that case, EMS staff would be subject to COVID-19 vaccination requirements in the IFC as applied to Long Term Care facility staff.

CMS has provided an FAQ on the vaccine mandate that speaks directly to this question.

 

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