A new requirement for surveyors to be vaccinated against COVID-19 comes with an important requirement for providers: You can’t ask surveyors to show proof of their vaccination status.
CMS is requiring that any surveyor who is not fully vaccinated should not participate in onsite surveys of certified providers and suppliers, including accreditation surveys performed under an accrediting organization’s deeming authority, according to the memo to state surveyors January 25, 2022 (QSO-22-10-ALL).
States should have a process by which staff may request an exemption based on medical contraindications or religious beliefs. Surveyors granted an exemption may continue to survey while observing additional safeguards “as determined and documented by the state.” That could include mandatory testing, limiting their onsite work to records review, work modifications, for example.
“The State Survey Agencies and AOs are ultimately responsible for compliance with this
expectation,” the memo notes. “Therefore, certified providers and suppliers are not permitted to ask surveyors for proof of their vaccination status as a precondition for entry.”
Providers may direct questions about the process a state or AO uses for vaccination and accommodations to the State Survey Agency or AO.