Additional CMS Rule Affecting 17 Million Health Care Workers Does Not Allow Testing Alternative
Large businesses with more than 100 employees now have just eight weeks to comply with COVID-19 vaccination and testing mandates or face massive fines. In a November 4 fact sheet, the Biden administration provided details on a January 4 deadline for two rules issued by the Occupational Safety and Health Administration (OSHA) and the Centers for Medicare and Medicaid Services (CMS) which will impact more than 101 million individuals nationwide.
Whereas the OSHA rule allows for weekly diagnostic testing alternatives to vaccination, the CMS rule – covering health care workers at facilities participating in Medicare and Medicaid – does not.
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The enormous burden of effectively tracking employee vaccines and weekly diagnostic tests throughout an entire organization falls on internal human resources departments. These HR professionals – the vast majority of whom are not trained in vaccination tracking — will need to successfully collect large amounts of personal data and medical records across their entire staff without accidentally exposing it and violating state and federal data privacy laws. Answers will need to be logged and managed for questions such as:
- Who received the vaccine?
- Does each individual have a legitimate proof of vaccination (and not a fraudulent vaccine card)?
- What was (were) the date(s) and manufacturer(s)?
- Will the individual need a booster?
- For those who don’t have the vaccine, are they getting weekly diagnostic testing; what are the results; and how are their results being collected?
- Does an individual qualify for a religious or medical vaccination exemption?
CastleBranch, a company that released its first COVID-19 solution in April 2020 to help organizations mitigate risk, has identified another stumbling block for these large employers. If the company’s vaccine and diagnostic test tracking process is not carefully documented, creating a secure audit trail, they may be at risk for thousands of dollars in fines per incident in the event of an alleged violation, putting that company’s economic survival in jeopardy.
To help large employers, colleges and universities, CastleBranch created an essential tool kit: RealVaccinationID.com and CB COVID-19 Compliance. Included in CB COVID-19 Compliance is the company’s Diagnostic Test Tracking solution, which helps organizations track the results of a diagnostic COVID-19 test via a secure, password-protected platform. The tool helps organizations protect the employee’s private data and information, and also provides a detailed audit trail to help protect the employers from potential liability. The solution can be paired with RealVaccinationID.com, which provides digital and physical proof of COVID-19 vaccination status while helping companies create a secure audit trail.
CastleBranch built this essential tool kit with inspiration and guidance from some of the world’s leading epidemiologists and pandemic disease policy experts. It’s also been endorsed by both the Organization for Associate Degree Nursing (OADN) and the American Association of Colleges of Nursing (AACN), the nation’s two largest nursing healthcare associations, representing more than 80 percent of nursing education in the country.
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