Series: Federal Vaccine Mandates and Responding to Exemption and Accommodation Requests

Access the on-demand series here.

Part 1: The CMS Vaccine Mandate – Compliance Requirements and Challenges for Health Centers

On November 4, 2021, the Centers for Medicare & Medicaid Services (CMS) issued an Interim Final Rule (IFR) requiring that health care workers at Medicare and Medicaid-certified facilities be vaccinated. It is estimated that more than 10,000 Federally Qualified Health Center sites will be covered by the CMS IFR. The IFR does not include a vaccine-or-test option; however, employees may request a religious or medical exemption and, if granted, employers must provide a reasonable accommodation. 

By December 6, 2021, covered facilities must develop and implement the required policies and procedures which must include the mandatory vaccination policy, tracking and securely documenting vaccination status and booster doses for all staff, and requesting a medical or religious exemption. The IFR also requires that all staff must receive a single dose COVID-19 vaccine or the initial does of a primary series by December 6, 2021.  

By January 4, 2022, all applicable staff must be fully vaccinated for COVID–19, except for those staff who have been granted exemptions from COVID–19 vaccination or those staff for whom COVID–19 vaccination must be temporarily delayed, as recommended by the CDC, due to clinical precautions and considerations.

As legal challenges threaten and the compliance deadlines loom, join FTLF for Part 1 of this webinar series which will include in-depth look at the CMS IFR that will provide information on whether the IFR applies to various types of employees, vendors, and volunteers (including Board members); suggestions on how to incorporate the IFR requirements into your health center’s policies and procedures (and whether to seek Board approval); and an expanded FAQ section based on questions received from health centers across the country.

Part 2:  Responding to Medical and Religious Exemption and Accommodation Requests

Under federal law, some health center staff members may be exempt from a health center’s vaccine mandate pursuant to the reasonable accommodation provisions of Title VII of the Civil Rights Act of 1964 (Title VII) and the Americans with Disabilities Act (ADA). There are two types of exemptions:

  • Religious exemptions for sincerely held religious beliefs, practices, and observances; and
  • Medical exemptions for certain disabilities.

Health centers must engage in an interactive process with employees to analyze exemption requests and, when an exemption is granted, to determine whether there is a reasonable accommodation that the health center can provide. Notably, the CMR IFR includes additional documentation requirements for medical exemption requests from staff members.

Navigating the process for analyzing exemptions and providing accommodations can be difficult and costly for health centers.  

As health centers receive and respond to exemption requests related to the vaccine mandates required under the CMS IFR, join FTLF for Part 2 of this webinar series in which we will explore best practices for handling exemption requests - from documenting the interactive process to the confidentiality requirements around the information received from employees.

Please note: This webinar series is offered at a discounted price of $300 for all Health Center Compliance 2021 Premium Plan Subscribers. For more information on our Premium Plan, click here or Contact Us.


Target Audience

  • CEOs, COOs, CMOs
  • Clinical Staff
  • Human Resources Managers and Staff
  • Risk Managers
  • Compliance Officers

Learning Objectives

Part 1

After this webinar, you will be able to:

  • Identify how the CMS IFR applies to health centers
  • Review your health center’s current vaccine policy and procedures for compliance with the CMS IFR
  • Understand how compliance with the CMS IFR will be evaluated

Part 2

  • Understand how medical and religious exemptions work under federal law
  • Develop documentation procedures that reflect the interactive process of evaluating medical and religious exemptions
  • Identify strategies to limit employment-related risk for your health center providers when mandating COVID-19 vaccines


Course summary
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A Partner in the firm’s health law practice group, Molly advises health centers on the management of clinical, employment and workforce-related risks, with a particular focus on professional liability, Federal Tort Claims Act, and HIPAA matters. From her experience as both a private attorney and in-house counsel, Molly knows the importance of managing liability and risk issues in mission-driven organizations. [Full Bio]


As Partner and Compliance Counsel with the firm’s health law practice group, Dianne advises health centers on implementing effective compliance programs and on addressing top compliance risk areas. Dianne counsels health centers and other organizations on developing compliance programs that include the OIG’s seven elements, respond to identified compliance risk areas, and reflect the organization’s culture.  Dianne also advises health centers and other organizations on patient privacy and confidentiality, including the HIPAA Privacy Rule and 42 CFR Part 2.  She has experience responding to privacy and security incidents, including determining whether there has been a breach, notifying patients and the government, and creating corrective action plans. [Full Bio]

Participants can earn up to 1.80 CPE credits in Specialized Knowledge and Applications per webinar upon completion of all course requirements.


If you purchase CPE credit for this webinar you must satisfy the following conditions in order to receive your certificate:

  1. Answer at least 6 of the 8 polling questions during each webinar
  2. Complete the evaluation survey after the conclusion of the webinar or in the follow-up email

Upon completion of these requirements, FTLF will email you your CPE Certificate within seven (7) business days.


  • Prerequisites: None 
  • Target Audience: CEOs, COOs, CMOs, Clinical Staff, Human Resources Managers and Staff, Risk Managers, and Compliance Officers
  • Advanced Preparation: None  
  • Program Level: All
  • Delivery Method: Group Internet Based
  • Attendance Requirements: In order to be awarded the full credits, you must respond to six (6) out of eight (8) polling questions per webinar.

Feldesman Tucker Leifer Fidell LLP is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website (formerly

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Access to the recorded version of this webinar series is included in your purchase.


The webinars in this course are only available for purchase as an entire webinar series. The recorded version of each webinar will be available in your account within seven (7) business days of each session and you will have access to the recordings for 180 days after the conclusion of the series. Once posted to your account, you can view each webinar anytime on-demand during the access period identified in your purchase confirmation. For additional information on viewing and accessing webinars, view our full terms and conditions here.


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For orders of live webinars, FTLF will issue a full refund for cancellations requested at least one week PRIOR to the live webinar. We do not provide refunds for no-shows; however, you will have access to the recorded version of the webinar. If you ordered the wrong webinar and need to transfer your registration to a different program, please Contact Us. View our full policy on refunds and cancellations on our FAQ page.

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