November 15, 2021

APMA is still in the process of reviewing the rules issued by CMS and OSHA. However, we address two of members’ FAQs below.

• My office serves Medicare patients referred to us for outpatient treatment. Does this mean all of my staff must be vaccinated?
• I prescribe and provide durable medical equipment (DME) in my private practice to patients as a physician DME supplier. Does this mean all of my staff must be vaccinated?

With outpatient physician offices, our and our consultants’ understanding is that if the physician office is independent and not a part of a hospital system, the CMS requirements would not apply. We understand the “contract/arrangement” language in the FAQs means services provided to the facility’s patients as part of the care the facility is delivering (e.g., contract nurses, physicians with admitting privileges, ER doctors who work in the hospital’s ER, etc.), not services provided based on referral. 

For physicians who prescribe and supply DME in their offices, CMS has indicated that DME suppliers are not covered by the vaccine mandate, but APMA cautions members to keep in mind that even if the CMS vaccine mandate does not apply to your office staff, the OSHA Healthcare ETS may still apply if they meet coverage criteria under the ETS. 

APMA will update its vaccine tab at www.apma.org/COVID19 as more information comes in. If you have questions, email the APMA Health Policy and Practice department at healthpolicy.hpp@apma.org.

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