cms covid vaccine mandate deadline

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A caregiver helps an older adult.(Rido81/Bigstock). James McDonald, M.D., M.P.H., Commissioner of the NYS Department of Health (DOH), has approved the DUR Board recommendations resulting in changes in NYS Medicaid coverage criteria for PADs. Find tips to protect patient health records and other data from cyberattacks. For a list of hospitals and ambulatory surgery centers where NYS Medicaid will not pay for breast cancer surgery, providers can refer to the NYS DOH "Hospitals & Ambulatory Surgery Centers Where Medicaid Will Not Pay for Breast Cancer Surgery" web page. NYRx coverage and policy questions should be directed to the NYS Medicaid Pharmacy Policy Unit by telephone at (518) 486-3209 or by email at, MMC general coverage questions should be directed to the OHIP Division of Health Plan Contracting and Oversight (DHPCO) by email at. Legislation has extended some of the pandemic-era changes beyond the end of the PHE and pending legislative and regulatory changes may extend some of the lessons of the pandemic farther into the future. Nursing home operators say that could lead to a mass exodus by workers. Effective April 1, each year, NYS DOH reviews facilities and releases an updated list that identifies low-volume facilities. Pennsylvania has said at least 80% of a nursing homes staff must be vaccinated by October; Delaware and New Jersey announced requirements that would cover all health care workers, with deadlines of late and early September respectively. From the staff list, surveyors will select a sample of direct care staff (both vaccinated and unvaccinated), contracted staff and direct care staff with documented exemptions. Most healthcare providers will need to modify their operations, procedures, and processes in some way to address the end of the PHE and the end of substantial flexibilities that have become entrenched over the past three years. If the COVID-19 PHE ends as expected on May 11, 2023, this coverage requirement will end on September 30, 2024. The COVID-19 federal public health emergencya separate declaration by the Secretary of Health and Human Services from January 2020remains in effect for now. DSMT claims must include a valid International Classification of Diseases (ICD)-10 code for diabetes mellitus. Additionally, MMC Plans will reimburse providers no less than the NYS Medicaid FFS rate for DSMT services and must cover the cost of DSMT services when rendered by qualified providers who do not participate in the network of the MMC Plan. / CBS News. For NYS Medicaid members enrolled in an MMC Plan, providers should check with the MMC Plan of the enrollee for implementation details, reimbursement fees, and billing instructions. Further details and analysis to follow. Practitioners accustomed to prescribing Schedule II-IV medications via telemedicine will need to ensure that in-person examination requirements are met. the pharmacy must be certified* to dispense mifepristone; the pharmacy may only dispense when the prescription is written by a practitioner certified to prescribe mifepristone; the pharmacy must be able to ship mifepristone in a timely manner using a shipping service that provides tracking information; the pharmacy submits a claim for only one course of therapy with no refills; and, New York State (NYS) laws, rules, and regulations; and. Same full vaccination targets as Group 1 (above). The virus caused severe illness and death in many nursing homes nationally, and the outbreak in the 247-bed, state-run facility in Holyoke was one of the deadliest. Questions regarding this policy should be directed to the Medicaid Pharmacy Policy Unit at. The COVID-19 vaccine mandate does not apply to staff who work exclusively offsite or remotely and who do not have any direct contact with patients or other staff. CMS notes that [w]hen determining whether to require COVID-19 vaccination of an individual who does not fall into the categories established by this [rule], facilities should consider the frequency of presence, services provided, and proximity to patients and staff.. Phase 1: In addition, private health insurers will be able to determine whether to cover testing and at what level. In bringing the charges against the men in September 2020, then-Massachusetts Attorney General Maura Healey, now the state's Democratic governor, touted the criminal case as the first in the country tied to a COVID-19 outbreak at a nursing facility. Staff will be deemed to have met the 60-day deadline if they receive the second/final dose of a primary vaccination series by the 60 th day even though they will not be considered fully vaccinated until 14 days after the second dose. Compliance program reviews will be for a defined period and will confirm the following: Initial compliance program reviews will encompass a three-month review period for months on or after April 1, 2023. Physicians answered questions in an online forum for parents concerned about sending kids back to school as cases rise in younger age groups. Pennsylvania has said at least 80% of a nursing homes staff must be vaccinated by October; Delaware and New Jersey announced requirements that would cover all health care workers, with Title II of the Americans with Disabilities Act (ADA), 42 U.S.C., 12131 et seq. But a judge dismissed the indictments pre-trial in 2021, saying the evidence presented to the grand jury was insufficient to show that the condition of the five veterans would have been different but for the merger as they had already been exposed to COVID-19. Thats something we just cant compete with.. Taking decisive measures to protect the health and safety of Washingtonians during the COVID-19 pandemic, resulting in one of the lowest death rates in the country. Drive in style with preferred savings when you buy, lease or rent a car. WebCDC and CMS Issue Joint Reminder on NHSN Reporting Healthcare Facility HAI Reporting Requirements to CMS via NHSN Current and Proposed Requirements January 2019 Listen to podcast updates on how the AMA is fighting COVID-19 by discussing the Supreme Court's decisions on vaccine mandates. CMS acknowledged that the vaccine missions might cause many We appreciate the recent guidance that All three states would allow unvaccinated staff to get regular COVID-19 testing instead. Please review: NACHC Operational Resource Guide COVID-19 Vaccine Mandate 3. All efforts to secure said services must be thoroughly documented. Questions regarding billing should be directed to the eMedNY Call Center at (800) 343-9000. We have a few contracts where some people were so below $15 that they were looking to other avenues to be able to cover their everyday expenses, but they would stay at those jobs because they love their residents., The minimum wage in Pennsylvania remains $7.25, which Gov. See how the CCB recommends changes to the AMA Constitution and Bylaws and assists in reviewing the rules, regulations and procedures of AMA sections. He said nursing homes could keep their staff if they paid them more, offered better benefits, and improved working conditions. WHYY is your source for fact-based, in-depth journalism and information. Because each matter is different, our past results cannot predict or guarantee a similar result in the future. The new regulations would apply to more than 15,000 nursing home facilities and 1.3 million workers. A PHE lasts for 90 days and must be renewed to continue; the PHE for COVID-19 has been renewed several times, most recently in February 2023, and is Why does information about vaccines and COVID keep changing? MMC ReimbursementThe "FFS Billing Guidance for Pharmacies" section referenced above is specific to NYS Medicaid FFS. Hospitals surveyed after their Phase 1 date should expect the surveyors to request two things: the organizations COVID-19 vaccine policies and procedures, and a list of all staff with their vaccine status. Now! It is imperative that members/enrollees are made aware of these changes as they may risk losing their coverage if appropriate actions to renew are not made. A parade of both federal and state regulatory waivers and flexibilities have supported, among other initiatives, the rollout of COVID-19 testing and vaccines, a tremendous growth in the utilization of telehealth services, maintenance of Medicaid enrollments without interruption, and flexibility for healthcare facilities in admitting and treating the sick. Medicaid is the primary payer for nursing home care in the United States, so the regulation would apply to most facilities. Is it the right decision for you? WebTRENTON Govern Phil Murphy today signed Executive Order No. DSMT services are reimbursable when provided by a pharmacy that has been accredited or recognized by a Centers for Medicare and Medicaid Services (CMS)-approved National Accreditation Organization (NAO). We conclude only that they will have the opportunity to do so.". All questions should be directed to NYS DOH at hcre@health.ny.gov. A decision by the U.S. Supreme Court should We must stabilize hospitals finances to ensure access to patient care. Medicaid providers may also face challenges as an estimated 5 to 14 million people are expected to lose Medicaid coverage during the unwinding of the continuous enrollment provision of the Families First Coronavirus Response Act. Despite the expiration of the PHE, Medicare, Medicaid, and private health insurance must continue to provide COVID-19 vaccines without cost sharing. Massachusetts' top court on Thursday revived the indictments against two former leaders of a veterans' home charged with criminal neglect for their roles in handling a COVID-19 outbreak that killed 84 people. On February 24, 2023 the DEA announced proposed rules for prescribing controlled substances via telemedicine after the PHE expires. Many nursing homes, which rely heavily on Medicare and Medicaid funding, have not imposed such requirements, and vaccination rates among staff have varied greatly by facility. (1/19/21) The regulation requires CMS facilities, like FQHCs, to The 12-month postpartum period begins on the last day of the pregnancy and ends on the last day of the 12th month. The AMA is leading the fight against the COVID-19 pandemic. U.S. health officials said the administration will be prepared to begin offering booster shots on September 20. April 21, 2023. Copyright 2022 ICP12000238-1 ICP12000238-2, 322. Individual practitioners can complete and submit this form electronically on the eMedNY "Provider Enrollment Portal" web page. For additional information regarding the COVID-19 PHE, providers can refer to the United States (U.S.) Department of Health and Human Services (HHS) Administration for Strategic Preparedness and Response (ASPR) "Declarations of a Public Health Emergency" web page. A research year during medical school affords students more time to follow their scholarly pursuits. That decision occurred at the onset of the deadly pandemic, before vaccines were available. As has been widely reported, both the CMS Rule and the ETS include a deadline of January 4, 2022, for covered employees to be fully vaccinated. With this phased approach, there are specific targets that must be met at 30 days (Phase 1), 60 days (Phase 2) and 90 days (full enforcement) with different enforcement dates for different groups of states. MMC Plan contact information can be found in the. The more than 6 million people who work there provide care, compassion and, The Centers for Disease Control and Prevention April 19 recommended a second Moderna or Pfizer COVID-19 bivalent vaccine dosefor adults aged 65 and older, The Department of Health and Human Services on April 19announced a $1.1 billion public-private partnershipto help maintain access to COVID-19, The House Energy and Commerce Health Subcommittee today held a legislative hearingon federal programs to strengthen the health care workforce and primary, CMS updates guidance on COVID-19 vaccine mandate for health care workers, Updates and Resources on Novel Coronavirus (COVID-19), Institute for Diversity and Health Equity, Rural Health and Critical Access Hospitals, National Uniform Billing Committee (NUBC), AHA Rural Health Care Leadership Conference, Individual Membership Organization Events, memorandum and provider-specific guidance, Standing Up for Patients and Protecting Access to Care, CDC: Monovalent vaccination was 76% effective at preventing mechanical ventilation, death in hospitalized COVID-19 patients during omicron, America Needs Strong Hospitals to Foster Healthy and Thriving Communities, CDC recommends second COVID-19 bivalent booster for older adults, immunocompromised, HHS announces plan to support continued access to COVID-19 vaccines, treatments for uninsured, House holds hearing on proposals to strengthen health care workforce, The Important Role Hospitals Have in Serving Their Communities, American Organization for Nursing Leadership. (See 86 FR 61569). Prosecutors accused Walsh and Clinton of elder neglect and of permitting serious bodily injury to an elder in the case of five veterans, saying the merger increased the danger they faced by putting them in "basically an incubator for COVID.". A trial of a conventional agent, disease-modifying anti-rheumatic drug (DMARD) or tumor necrosis factor inhibitor (TNFi), Food and Drug Administration (FDA)-approved for self-administration prior to initiation of infliximab, in accordance with FDA package labeling or compendia-supported use. Questions regarding the Disability Advocates Inc. (DAI) Settlement should be directed to the NYS DOH Office of Community Transitions by email at, Questions regarding AH+ care coordination can be directed to the AH+ program by email at. Primary election 2023 voters guide: These are the candidates running for Pennsylvania courts, Corvallis: Oil, Lube and Filter Change For Seniors, NC Supreme Court Rolls Back Voting Rights: Voter ID Reinstated, People With Felonies Cant Vote And Partisan Gerrymandering Is Back, Massachusetts organization builds houses free of charge for disabled veterans, This Supreme Court is slow to issue rulings glacially slow. Hospitals are competing for staff as well, and some are considering not mandating vaccinations to keep employees, according to Kaiser Health News. Providers can also contact the eMedNY Call Center at (800)343-9000 for assistance. WebThe Biden administration COVID-19 action plan, also called the Path out of the Pandemic, is a substantial increase in the use of vaccination mandates as part of the U.S. federal WHYY offers a voice to those not heard, a platform to share everyones stories, a foundation to empower early and lifelong learners and a trusted space for unbiased news. Despite the expiration of the PHE, Medicare, Medicaid, and private health insurance must continue to provide COVID-19 vaccines without cost sharing. A mandate that applies to all health care settings would be better than one that just applies to nursing homes, said Andy Aronson, president and CEO of the Health Care Association of New Jersey, the trade group for long-term care providers. "Of course, sometimes bad things happen for no discernable reason, and no one is to blame," Justice Dalila Argaez Wendlandt wrote for the majority. Want a digest of WHYYs programs, events & stories? The AMA Update covers a range of health care topics affecting the lives of physicians and patients. Per the settlement agreement, settlement providers, including MLTC Plans, must educate class members about their right to move to community settings and thoroughly document those conversations. Washington President Biden announced Wednesday he is ordering the Department of Health and Human Services (HHS) to require nursing homes to have vaccinated staff for them to be able to participate in Medicare and Medicaid and receive funding from the federal programs. Renewal notices will include the deadline to take action to renew their insurance or risk having a gap in coverage. Many business have shoved back against vaccine mandates out of fear is employees will quit. In fact, the reason most people in America don't worry about polio, small pox, measles, mumps or rubella today is because of vaccines.". WHYY provides trustworthy, fact-based, local news and information and world-class entertainment to everyone in our community. PAXpress is a web-based pharmacy PA request/response application, accessible through the "PAXpress" button, located on eMedNY homepage, under the "eMedNY Tools Center" drop-down button. The CMS COVID-19 vaccine mandate applies to all staff who provide any care, treatment or other service for a hospital or its patients. Resources include the following: NYS Department of Health (DOH) encourages all providers, local districts, stakeholders, and advocates to access and use these communication tools and share with members/enrollees. CMS acknowledged that the vaccine missions might cause many healthcare workers to leave them jobs, but ultimately concluded that the risks posed by COVID-19 outweighed any losses due to employee departures. All rights reserved. Enter the pharmacist National Provider Identifier (NPI) number, 454-EK (Scheduled Prescription ID Number). A lawyer for Clinton declined to comment. In addition to general billing rules applicable to all pharmacy claims, the following rules apply when submitting a pharmacy claim for mifepristone: *To certify, a pharmacy must have submitted to the manufacturer a completed Pharmacy Agreement form relevant to the product dispensed, either the brand Mifeprex or the generic mifepristone. August 19, 2021 / 7:33 AM On Jan. 13, 2022, the U.S. Supreme Court permitted the Centers for Medicare & Medicaid Services (CMS) to enforce its interim final rule requiring many James McDonald, M.D., M.P.H., Commissioner of the NYS Department of Health (DOH), has approved the DUR Board recommendations resulting in changes to the NYRx coverage criteria for the following drugs. Listen to podcast updates on how the AMA is fighting COVID-19 by discussing the importance of prioritizing clinician well-being in the COVID new normal.. Consumers will be renewed at the end of the 12-month postpartum period. All rights reserved. Find information about CPT Category I Vaccine Codes. If a governor cuts a teacher's salary for disobeying a mask mandate, something Florida Governor Ron DeSantis has threatened to do, the president said money from the American Rescue Plan "can be used to pay that person's salary, 100%.". Associate Dan Kadish told the Associated Press thatthe December 27 deadline for New York City Mayor Bill de Blasios new vaccine mandatewhich requires all employees who perform in-person work for private businesses in New York City to receive at least one dose of a COVID-19 vaccine by December 27does not give These policies and procedures must include the following ten components: A phased approach to enforcement began January 27 for hospitals in Group 1 states. Dive Brief: CMS is extending the vaccine deadline for healthcare facilities in 24 states following last week's Supreme Court decision upholding the requirement that Providing more affordable health care options to all Washingtonians by making Washington one of the 10 leading states for fully implementing the Affordable Care Act and expanding eligibility for For skilled nursing facilities, waivers of the requirement for a three-day prior inpatient hospitalization and prior Medicare coverage of a skilled nursing facility stay will expire, along with other pandemic-era changes to requirements for testing, room assignments, etc. Each month, the Senior Physician Sectionhighlights membersand individualsto showcase their work and current efforts. "At any subsequent trial, prosecutors will need to prove their case. MMC reimbursement, billing, and/or documentation requirement questions should be directed to the MMC Plan of the enrollee. Drugs listed in the Physician Manual Fee Schedule, with a notation of BR (By Report) under the "Maximum Fee" column, must be submitted on the Health Care Finance Administration (HCFA) 1500 claim form (via paper) with a copy of the itemized invoice as documentation. The AMA is leading the fight against the COVID-19 pandemic. U.S. health officials Wednesday announced plans to offer COVID-19 booster shots to all Americans to shore up their protection amid the surging delta variant and signs that the vaccines' effectiveness is falling. They stay at the facilities that they are, not solely for the money, its about the love of the game, but we want to also compensate those employees fairly, Ford said. MMC Coverage PolicyThe "FFS Coverage Policy" section referenced above also applies to all types of MMC Plans. Special Report: Biden speaks on COVID-19 vaccines, boosters and nursing homes, Does "Arcturus" COVID variant cause pink eye? In honor of Older Americans Month (May 1-31, 2023), the AMA celebrates senior physician members (ages 65 years and above). FFS pharmacy and PAD coverage policy questions should be directed to the Medicaid Pharmacy Policy Unit by telephone at (518) 486-3209 or by email at, Additional information on the DUR Board is available on the. The ADA, as interpreted by the Supreme Court in the landmark decision, Olmstead v. (Reporting by Nate Raymond in Boston and Brendan Pierson in New York, Editing by Alexia Garamfalvi and Matthew Lewis), American judge; Associate Justice of the Massachusetts Supreme Judicial Court, Man who lost wife, son in Texas mass shooting tells story, E. Jean Carroll resumes testimony in Trump rape trial after mistrial denied, Michael J. Various waivers intended to reduce administrative burdens related to Hospital Conditions of Participation (i.e., equipment inspections, medical records, etc) will be removed. Stephen Crystal, director of the Rutgers Center for Health Services Research and an expert on long-term care, said a COVID-19 vaccine mandate across all health care settings was overdue. Judging from states that have already enacted mandates on their own, Biden administration officials have said they do not expect mass resignations in response to the CMS regulations. The Philly Joy Bank is modeled after similar programs in Canada and San Francisco that offer guaranteed cash income to pregnant residents. CMS Plans Enforcement, Sets New Deadlines for COVID Vaccination Mandate Thursday, December 30, 2021 The Centers for Medicare & Medicaid Services Effective April 27, 2023, prescribers must ensure patients do not have an advanced disease (e.g., complete limb paralysis or permanent ventilator dependence) before prescribing risdiplam (Evrysdi). It is not yet clear what the deadline is for nursing staffs to make the requirement or for staffs to be fully vaccinated in order to continue receiving federal funds. U.S. health officials said the administration will be prepared to begin offering booster shots on September 20. Our facilities residents also use other parts of the health care system, including hospitals, including doctors offices, dialysis centers, and other places, and just like they should have the comfort of knowing that their workers in long-term care facilities are vaccinated, they should have the comfort of knowing that their workers at other health care settings are also vaccinated, Aronson said. Listen to podcast updates on how the AMA is fighting COVID-19 by discussing what to expect with the Omicron surge. Beginning July 2023, OMIG will initiate compliance program reviews to determine if required providers have adopted, implemented, and maintained an effective compliance program as required by 18 NYCRR Part 521, located in the OMIG Summary of Regulation document. 100% staff have received at least one dose or have documented exemption granted or pending; OR, On track to 100% vaccination by deadline and at least, 100% staff have completed vaccination OR have documented exemption granted or pending; OR. They Refused to Fight for Russia. 794, NYS DOH "Hospitals & Ambulatory Surgery Centers Where Medicaid Will Not Pay for Breast Cancer Surgery" web page, NYS DOH "Hospitals & Ambulatory Surgery Centers Where Medicaid Will Pay for Breast Cancer Surgery" web page, U.S. FDA "Information about Mifepristone for Medical Termination of Pregnancy Through Ten Weeks Gestation" web page, eMedNY "5010/D.0 Transaction Instructions" web page, NYS DOH "New York State Medicaid Managed Care (MMC) Pharmacy Benefit Information Center" website, NYS DOH "Drug Utilization Review (DUR)" web page, NYS DOH "Welcome to NYRx, the Medicaid Pharmacy Program" web page, Magellan Inc. NYRx, the Medicaid Pharmacy Program website, NYS DOH "New York State Medicaid Fee-for-Service Practitioner Administered Drug Policies and Billing Guidance" web page, New York State (NYS) Department of Health (DOH) "New York State Medicaid Fee-for-Service Practitioner Administered Drug Policies and Billing Guidance" web page, eMedNY "Applied Behavior Analysis (ABA)" web page, James V. McDonald, M.D., M.P.H., Acting Commissioner, Multisystem Inflammatory Syndrome in Children (MIS-C), Addressing the Opioid Epidemic in New York State, Health Care and Mental Hygiene Worker Bonus Program, Maternal Mortality & Disparate Racial Outcomes, Help Increasing the Text Size in Your Web Browser. President Biden signed into law a House bill on April 10 that immediately ended the COVID-19 presidential declaration of national emergency established in March 2020. Beginning in Spring 2023, renewal notices will be sent to members/enrollees based on their enrollment end dates. While the memorandum specifically applies to Texas, the guidance and rule apply to all states. (Reuters) - Massachusetts' top court on Thursday revived the indictments against two former leaders of a veterans' home charged with criminal neglect for their roles in handling a COVID-19 outbreak that killed 84 people. 2023 by the American Hospital Association. Diabetes outpatient self-management training services, group sessions (two to eight patients), per 30 minutes. Deadlines will be based on the member/enrollee enrollment end dates and will range from June 30, 2023, through May 31, 2024. The proposed rule has garnered over 35,000 comments for the DEA to consider in crafting the final regulations, expected sometime in 2023. Effective April 27, 2023, providers must ensure patients do not have an advanced disease (e.g., complete limb paralysis or permanent ventilator dependence) before providing nusinersen (Spinraza), via the medical benefit. To request permission to reproduce AHA content, please click here. In late December 2021, the Centers for Medicare & Medicaid Services Failure to inform the NYS DOH may result in termination of enrollment. But it has also left patients with more questions than answers. CMS may enforce its COVID-19 vaccination mandate nationwide after a federal court on Jan. 19 dismissed a lawsuit filed by the state of Texas, Bloomberg Law reported. On November 4, 2021, the Centers for Medicare and Medicaid Services (CMS) issued the Omnibus COVID-19 Health Care Staff Vaccination Interim Final Rule requiring staff at Medicare and Medicaid-certified facilities to be vaccinated unless they have approved religious or medical exemptions. MMC Plan contact information can be found in the, MMC Plan-specific policies and billing guidance for practitioner administered drugs (PADs) can be found on the, DUR Board information is available on the. WebRenewal notices will include the deadline to take action to renew their insurance or risk having a gap in coverage. A high-volume facility is defined as a hospital or ambulatory surgery center defined averaging 30 or more all-payer surgeries annually over a three-year period. President Joe Biden speaks from the East Room of the White House in Washington, Wednesday, Aug 18, 2021, on the COVID-19 response and vaccination program. New data from the CDC released Tuesday warned of a "significant decline" in vaccine effectiveness against COVID-19 in nursing home residents, who were vaccinated earliest in the nation's rollout of the COVID-19 vaccines. Ashvin Gandhi, a health economist at the University of California Los Angeles Anderson School of Management, did the research on annual turnover. This pocket guide is a free resource for employers and HR professionals that summarizes key Virginia statutes and employment law principles. According to the CMS Surveyor Guidance, if a surveyed facility does not meet the phased vaccination targets (see TABLE 1), is observably noncompliant with infection control practices, and has not developed or implemented one or more components of the policies and procedures, that hospital would earn a Condition Level deficiency with Immediate Jeopardy, which would result in penalties on an accelerated schedule. First published on August 18, 2021 / 3:31 PM. Research earlier this year found that the mean annual turnover rates for nursing home staff reached 128% and that nursing home staffing levels did not change significantly during the pandemic. Review the reports and resolutions submitted for consideration at the 2023 Annual Meeting of the AMA House of Delegates. Where state prescribing rules are more restrictive than the federal law, the more restrictive provision will apply. Of course, the results we have achieved depend upon a variety of factors unique to each matter. Mask requirements are disappearing, which is exciting for some. In 2013, a group of disability advocacy organizations and the U.S. Department of Justice filed a lawsuit (O'Toole v. Cuomo, 13-cv-04166) on behalf of persons diagnosed with SMI residing in twenty-three specific Impacted Adult Homes in New York City (NYC). The April 1, 2023 pharmacy benefit transition only applies to the NYS Medicaid pharmacy benefits. The 12-month postpartum period is available to all pregnant consumers, regardless of how their pregnancy ends. Explore how to write a medical CV, negotiate employment contracts and more. has an ownership interest totaling five percent or more in a disclosing entity; has an indirect ownership interest equal to five percent or more in a disclosing entity; has a combination of direct and indirect ownership interests equal to five percent or more in a disclosing entity; owns an interest of five percent or more in any mortgage, deed of trust, note, or other obligation secured by the disclosing entity if that interest equals at least five percent of the value of the property or assets of the disclosing entity; is an officer or director of a disclosing entity that is organized as a corporation; is a partner in a disclosing entity that is organized as a partnership.

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cms covid vaccine mandate deadline