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Immunizations: What is Required and What is Not

With annual immunization season upon us, LeadingAge Iowa has received many questions about the regulatory requirements for offering and administering vaccines.

F883 requires nursing homes to assess, offer and facilitate administration of Influenza and Pneumonia vaccinations according to the CDC recommendations.

  • Upon admission, nursing homes must assess whether the resident has received the current recommended vaccinations for both influenza and pneumonia. (Note the influenza vaccine season is October 1 through March 31 annually.)
  • If the resident has not received the recommended vaccines, the nursing home must education (such as providing the Vaccine Information Statements).
  • The nursing home must also offer the vaccines if the resident is not current with either vaccine. This should include a consent for both vaccines as applicable.
  • If the resident or the responsible party consents to the vaccine, the nursing home should administer if able or facilitate administration such as scheduling an appointment and arranging transportation to/from the appointment to receive.
  • This process must be completed annually for influenza vaccines and when CDC revises pneumonia vaccination recommendations.
  • Note that F883 is only related to resident vaccines and does not include staff.
  • All documentation must be maintained to prove compliance.

Note that pneumonia vaccine recommendations were revised in 2022 to include PCV15 or PCV20 in addition to the PPSV23 vaccine dose. You can view current recommendations in the LeadingAge Iowa Pneumonia Vaccine Policy Template based on the individuals age and history of pneumonia vaccines to ensure compliance.

F887 requires nursing homes to assess, offer, and facilitate administration of COVID-19 vaccines to both staff and residents. Similar to F883 the regulation requires:

  • Assessing both staff and residents for receipt of current recommended COVID-19 vaccines. The current recommendations include receipt of the 2023-2024 formula COVID-19 vaccine. If the resident or staff chooses they can also receive Novavax.
  • If the resident or staff is not up to date with their COVID-19 vaccine, education (such as the VIS) shall be provided.
  • The regulation does not state that a consent/declination must be obtained, but this is a best practice to provide documentation of compliance.  
  • If the resident or staff consents to administration, the nursing home shall administer if able, or facilitate administration of the vaccine. This could include scheduling an on-site vaccination clinic or facilitating off-site vaccination including locations where staff can receive the vaccine. If a resident, the nursing home must assist with scheduling an appointment and transportation to/from the vaccine appointment as appropriate.
  • Documentation shall be maintained of all efforts to assist with COVID-19 vaccines.

For both F883 and F887 the regulations don’t require the nursing home to bear the cost of the vaccinations. In accordance with Medicare, some vaccines may be administered by the nursing home and billing Medicare for the vaccine and administration while other vaccines may not be allowed. It is best to discuss with your long-term care pharmacy what options are available and plan accordingly to avoid unnecessary expenses to the nursing home. Numerous nursing homes provide influenza vaccines at no-cost to staff, however, this will also be an internal decision that should be made by leadership at the nursing home and is not required.

While there are not regulations pertaining to RSV or other potentially beneficial vaccines, nursing homes should discuss with the resident’s primary physician to determine if the resident would be appropriate for receipt of the vaccine. If the primary physician believes the resident should be vaccinated (this would include other vaccines such as Shingles), the nursing home should assist with scheduling an appointment and transportation to receive these vaccines.

The OSHA Bloodborne Pathogen standards also require that staff are offered the Hepatitis B vaccination at no cost to the staff member. The standards also state that the vaccine must be made available at a reasonable time and place and performed under the supervision of a licensed physician or other healthcare professional. Nursing homes should have a process for receiving a standing order from the medical director or the person completing the employee physical prior to employment for the hepatitis B vaccine based on the individual. Consideration must be made for staff members who are minors and receipt of a parent or guardians’ consent for vaccination.

Resources:

LAI - Pneumonia Vaccine Policy and Procedure template