LeadingAge Resources for Compliance with Interim Final Rule

LeadingAge Resources for Compliance with Interim Final Rule

On May 11, 2021, CMS released interim final rule CMS-3414-IFC requiring nursing homes and intermediate care facilities for individuals with intellectual disabilities (ICF/IIDs) to educate and offer COVID-19 vaccination to all residents and staff. The rule additionally requires nursing homes to report vaccination rates for residents and staff and resident use of therapeutics to the National Healthcare Safety Network (NHSN). This rule goes into effect May 21, 2021.

CMS has outlined in memo QSO-21-19-NH survey protocols for assessing compliance with these requirements. Specifically, CMS will investigate how residents and staff are educated about and offered the COVID-19 vaccine, including reviewing samples of education materials, sign-in sheets from in-services provided, and interviewing residents and staff.

Additionally, surveyors may review information provided to residents and staff in the event that the provider was unable to immediately offer the COVID-19 vaccine, including information on alternative methods the resident and staff may engage in to access vaccine, as well as attempts the provider made to obtain vaccine.

Compliance with reporting requirements will be assessed through off-site data review.

To assist providers in compliance with these requirements, CMS has recommended a number of resources, compiled below along with additional helpful resources.

See full document here.




Laura Hofmann, MSN, RN – Director of Clinical and Nursing Facility Regulatory Services
c: 425-231-4804


May 24, 2021