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Memorial Regional Health issues letter on vaccine requirement for health care workers

MRH is working to diminish the strictness of the orders, but will require employees to get vaccinated if nothing changes

The Memorial Hospital at Craig
Cuyler Meade / Craig Press

In a letter to the community, Jennifer Riley, chief operating officer at Memorial Regional Health, outlined the new COVID-19 vaccine requirement policy as mandated by state and federal officials.

On Aug. 30, the Colorado Department of Public Health and the Environment’s board of health voted 6-1 to legally require vaccination for all licensed health care facilities in the state. This would require MRH to comply and direct employees, contractors and staff to receive the vaccine, and those who do not receive the vaccine by a certain date can no longer be employed.

Some employees are eligible for limited exemptions, but those who are not must receive their first shot by Sept. 30. Boosters will also be required if recommended by the Advisory Committee on Immunization Practices. Those who qualify for those exceptions will be required to comply with CDPHE COVID-19 testing regulations.



“Behind the scenes, MRH has been working with the Colorado Hospital Association and Senator Bob Rankin to request that the COVID-19 Vaccination Regulations be modified based on the burden placed on rural healthcare hiring, staffing and retention at our facilities,” Riley’s letter reads. “We know that passage with a 6-1 majority, the COVID-19 Vaccination Regulations were unlikely to be overturned. At the request of MRH, and many of our peer hospitals on the western slope, Senator Rankin appealed to the CDPHE on our behalf.”

The letter features a passage from Rankin, who said that the rural health care system in Colorado is “fragile.” Rankin cited severe stress and lack of health care options for his rural constituents as reasons to add a flexible waiver process for employees. This means hospitals could still operate while employees choose whether or not to get the vaccine.



“Perhaps it can be based on access to critical services,” Rankin said in the letter. “I suggest that the mandate allow for a threshold of 90% vaccinated in line with the current flu vaccine requirement. And please relax the time requirement. Don’t react to the current COVID surge and damage our health care system for a long time into the future.”

In addition to state regulations, MRH “cannot ignore” regulations or mandates created by the Centers for Medicare and Medicaid Services (CMS). Earlier this week, President Joe Biden ordered that all CMS facilities comply with a 100% vaccination rate in order to receive federal money. Riley also said that around 66% of the hospital’s revenue comes from payments made by CMS.

This rule would cover an “overwhelming majority” of healthcare facilities in the U.S., Riley wrote.

“Any hope for altering the CDPHE COVID-19 Vaccination Regulations changed on September 13, 2021, when the Biden administration announced a new policy to be set by the federal Occupational Safety and Health Administration (OSHA), which focuses on much of the news and controversy,” Riley wrote. “The proposed rule will require all businesses with 100 or more employees to either achieve 100% vaccination rates or require weekly testing of unvaccinated employees.”

This rule, however, does not apply to governmental entities, so Moffat County Government is not subject to this federal OSHA standard. CMS entities could attempt to challenge Biden’s direction in court, but Riley said they would likely be unsuccessful.

On Monday, MRH leadership met with representatives from the Colorado Hospital Association to discuss the new mandates. In that meeting, Riley said, CHA representatives said that CDPHE would be “carefully reviewing” each facility’s medical or religious exemptions to prevent any unsubstantiated or disingenuous avoidance toward the vaccine. Facilities found to be avoiding regulations would be “exposed to severe legal and financial repercussions.”

“As healthcare providers, we understand that our top priority is to do everything we can to provide high quality care to our patients in a safe environment. This mandate is exasperating short staffing levels all over the State of Colorado and is specifically troublesome in rural America,” Riley’s letter says. “MRH will continue to work hard to offer high quality health care for all of Moffat County and the surrounding communities that it serves while it complies with these new regulations and challenges.”

However, Riley in the letter acknowledged that the orders cannot be overlooked.

“Approximately 66% of our revenue is based on payments from CMS,” the letter reads. “MRH cannot ignore these changes and will be surveyed in person by our accreditation body to demonstrate compliance.”


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