Vaccination Expectations for Surveyors

The Centers for Medicare & Medicaid Services (CMS) recently updated its vaccination expectations for surveyors.  In January of this year CMS issued a memo (QSO-22-10-ALL) requiring state agency surveyors and accrediting organization (AO) surveyors performing deemed status surveys to not participate in onsite surveys unless fully vaccinated (unless vaccination is medically contraindicated or the individual is legally entitled to a reasonable accommodation under federal civil rights laws because they have a disability or sincerely held religious beliefs, practices, or observances that conflict with the vaccination requirement).

That memo whas been rescinded.

With QSO-22-18-ALL CMS encourages surveyors conducting federal surveys to be vaccinated but does not require it (or an acceptable exemption).  It remains up to the survey entity to implement policies around COVID-19 vaccination (and exemptions).

Previous guidance for surveyors entering nursing homes was provided in QSO-20-39-NH and this guidance remains.  While it is not directly applicable to home health and hospice providers, it may be applicable to some hospice inpatient facilities. Additionally, some state survey agencies and AOs have incorporated this guidance into their policies and procedures. It is expect that home health and hospice providers will not request vaccination status of surveyors or restrict surveyor access based on vaccination status.