Client Alert: Mandatory Covid-19 Vaccinations for Covered Entities


By Patrick Formato, Barbara Phair, Frank Mazzagatti and Jonathan Rogoff

The New York State Department of Health (“DOH”) issued an Order for Summary Action effective as of August 18, 2021 (“Order”). Article 28 general hospitals and nursing homes (“Covered Entities”) are now required to immediately implement and comply with the Order pursuant to Public Health Law (PHL) § 16.

Covered Entities must require all covered personnel to be fully vaccinated against COVID-19 with the first dose for current personnel received by September 27, 2021. The Order allows for limited medical and religious exemptions.

Vaccinations must be documented in personnel records or other appropriate records in accordance with applicable privacy laws, except where there is a limited exemption to vaccination.

In addition to reporting requirements, Covered Entities must develop and implement a policy and procedure to ensure compliance with the provisions of the Order.

The link to the Order for Summary Action is below.

DOH Order COVID-19 Vaccine Mandate 8.18.21

The healthcare attorneys at Abrams Fensterman are committed to providing you with the most current and accurate information and guidance. If you have any questions, please contact Patrick Formato, Esq., Barbara Stegun Phair, Esq., Frank Mazzagatti, Esq., Michael Bass, Esq., Richard Thomas, Esq., Jonathan Rogoff, Esq., or any other attorney in our health law practice group.

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