Mary Madison, RN, RAC-CT, CDP
Clinical Consultant – Briggs Healthcare
Late afternoon Friday, January 14, 2022, CMS posted QSO-22-09-ALL for the remaining 24 states not already covered by QSO-22-07-ALL. See the 4th bullet in the Memorandum Summary below:

The remaining state not covered by the Omnibus COVID-19 Health Care Staff Vaccination regulation – Texas – is still covered by a separate preliminary injunction issued in a district court there.
QSO-22-09-ALL is very similar to QSO-22-07-ALL in terms of content but differs in the timing of compliance. In short, the 24 states identified in this QSO must have employees fully vaccinated by March 15, 2022.
As found with QSO-22-07-ALL, there are provider-specific attachments that contain the F888 interpretive guidance (LTCFs; other providers have their Federal tag identified) details:
- Attachment A. LTC
- Attachment B. ASC
- Attachment C. Hospice
- Attachment D. Hospital
- Attachment E. PRTF
- Attachment F. ICF-IID
- Attachment G. HHA
- Attachment H. CORF
- Attachment I. CAH
- Attachment J. OPT
- Attachment K. CMHC
- Attachment L. HIT
- Attachment M. RHCFQHC
- Attachment N. ESRD
I encourage you to download the QSO that applies to the state your facility as well as the corresponding attachment. If you’re a corporate entity and have facilities in multiple states, both QSO Memorandums will need your attention and action.
QSO-22-07-ALL (December 28, 2021) | QSO-22-09-ALL (January 14, 2022 |
California | Alabama |
Colorado | Alaska |
Connecticut | Arizona |
Delaware | Arkansas |
Florida | Georgia |
Hawaii | Idaho |
Illinois | Indiana |
Maine | Iowa |
Maryland | Kansas |
Massachusetts | Kentucky |
Michigan | Louisiana |
Minnesota | Mississippi |
Nevada | Missouri |
New Jersey | Montana |
New Mexico | Nebraska |
New York | New Hampshire |
North Carolina | North Dakota |
Oregon | Ohio |
Pennsylvania | Oklahoma |
Rhode Island | South Carolina |
Tennessee | South Dakota |
Vermont | Utah |
Virginia | West Virginia |
Washington | Wyoming |
Wisconsin |