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Clearpol's Opinion of this Guidance as of 01/25/2022
QSO 22-10-ALL
The Quality, Safety & Oversight Group and Survey & Operations Group, in its guidance to State Survey Agencies, has expanded on the exclusionary criteria for all surveyors (including CLIA and Life Safety Code surveyors) entering provider locations to include vaccination status, effective in 30 days. Surveyors who have a COVID-19 vaccination exemption may continue surveying while observing additional safeguards, such as mandatory testing and limitation to conducting survey activities that limit resident contact. All surveyors are expected to use appropriate PPE while surveying. Surveyors who are not fully vaccinated should not participate as part of the onsite survey team performing federal oversight of certified providers and suppliers.
As stated in previous CDPH AFL guidance, CMS states that, certified providers are not permitted to ask surveyors for proof of their vaccination status as a precondition for entry. A SNF should still screen for COVID-19 symptoms, as it does for any visitor.
Clearpol Inc. does not make any guarantees regarding the accuracy of the opinions provided on our platform. Please use your own judgement.
Clearpol's Summary of this Guidance

The Centers for Medicare & Medicaid Services (CMS) issued a memo on January 25, 2022, outlining vaccination expectations for surveyors performing federal oversight at healthcare facilities. The memo states that surveyors who are not fully vaccinated should not participate in onsite survey teams, unless they have a medical contraindication or a legally recognized exemption. Unvaccinated personnel may still be used for offsite survey or enforcement activities. State Survey Agencies and Accrediting Organizations (AOs) must have a process for staff to request exemptions and reasonable accommodations. Surveyors with exemptions may continue surveying with additional safeguards, such as mandatory testing or limited patient contact. The memo emphasizes that all surveyors are expected to use appropriate personal protective equipment (PPE) while surveying. Healthcare facilities are not permitted to ask surveyors for proof of vaccination status. The memo's guidance is to be implemented within 30 calendar days of issuance.
Clearpol Inc. does not make any guarantees regarding the accuracy of the opinions or summaries provided on our platform. Please use your own judgement.
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