Immediate Jeopardy Survey Citations for Failure to Meet COVID-19 Vaccination Requirements in CMS Interim Final Rule Have Begun

The Pennsylvania Department of Health has begun citing nursing homes for failure to comply with the CMS Interim Final Rule requirements relating to COVID-19 vaccination of staff and policies and procedures.  Immediate Jeopardy citations require notice to attending physicians and to the NHA Licensing Board.  If you have questions about compliance with the requirements, including policies to deal with unvaccinated employees and requests for exemptions, you may contact Daniel K. Natirboff, Esquire ( or Bruce G. Baron, Esquire ( at our Firm.