Q: I’m a health care facility under the new CMS vaccine guidelines. We have a lot of volunteers who come through. Do they need to be vaccinated? 

A: The new omnibus regulations indicate consistently that students, trainees, and volunteers must be vaccinated. However, it is anticipated that the same rules we apply to things such as TB testing are likely to apply to any vaccine mandate. For example, if the local third grade class is coming in to sing carols in your atrium, vaccine information is unlikely to be needed. Those who come into direct contact with patients or will consistently provide volunteer services should be part of your vaccination program. Again, think about how you manage your TB testing and apply this to the circumstance until we receive further specific guidance.