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Capitol Correspondence - 06.24.25

CMS Issues Notice for Public Comment on Vaccination Documentation Requirements for ICFs

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The Centers for Medicare and Medicaid Services (CMS) has published a notice pertaining to documentation requirements for COVID-19 vaccinations in Intermediate Care Facilities for Individuals with Intellectual Disabilities (ICFs-IID). This notice comes after the rollback of a prior rule. Previously, CMS had required ICFs-IID to document that their staff and clients were educated and offered the COVID-19 vaccine and also document whether their staff received a vaccination or were approved for an exemption. Currently, ICFs-IID are not required to document whether staff receive a vaccination or whether they utilized an exemption; however, they are still required to educate both staff and clients on the risks and benefits of the COVID-19 vaccine and offer the vaccine to both clients and staff. This notice asks whether the staff documentation requirement should be reinstated. 

The comment period is open until July 17 ,2025. For more details, please see the full notice in the Federal Register. 

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