Recent Policy Updates

OSHA COVID-19 Vaccination Requirements 

Date: November 17, 2021  


OSHA is temporarily suspending enforcement of its Emergency Temporary Standard (ETS) vaccination requirements on all employers with 100+ employees.  The ETS was announced in September and in early November deadlines were set for immediate implementation.   See OSHA Statement on ETS 


The suspension was imposed due to ongoing litigation and the Biden Administration has encouraged businesses to continue implementing vaccination requirements.  There are a number of court challenges pending on the OSHA rule and a temporary stay was issued by the 5th U.S. Circuit Court of Appeals.  After the recent ruling, the Justice Department requested that all pending litigation be combined for speedy resolution of this issue 


UCA will keep you informed on any new developments.  

UCA has also responded to related Federal Register proposed rule change regarding the 2021 CMS Proposed CMS Physician Fee Schedule changes. See UCA Comments.

Over the past year, UCA has worked closely with a number of federal agencies including the Centers for Disease Control and Prevention (CDC), the Centers for Medicare & Medicaid Services (CMS) and various HHS agencies leading efforts on emergency preparedness.  We have partnered with a number of external stakeholders to advocate on behalf of our members and to ensure that any federal regulatory policies impacting the urgent care industry and our ability to treat patients, improve reimbursement policies on point of care testing and other administrative barriers are addressed in a timely fashion.

In addition to encouraging members to voice their concerns to lawmakers through grassroots advocate alerts, UCA hosted a Congressional Briefing and Lobby Day in March 2021 to educate members of Congress on some of the reimbursement challenges regarding COVID-19 point of care testing.  In conjunction with our Congressional briefing, UCA created a “50 state, 50 stories” education campaign highlighting urgent care centers in every state.

Also, UCA met with various regulatory agencies including CMS and MACs to encourage increased reimbursement rates for point of care testing.  Urgent care expenses for providing rapid testing exceeds reimbursement rates.  This has a detrimental impact on our ability to provide point of care testing to patients who need immediate results. 

Over the past year, urgent care centers have continued to treat a record volume of patients requiring COVID-19 testing.  However, urgent care centers are still facing reimbursement challenges. 

We are advocating for congressional action to increase reimbursement of point of care testing to cover the expenses of diagnostics and to ensure that patients have access to a full spectrum of diagnostics.  UCA leaders have met with key members of Congress, held congressional briefings, virtual UCA Lobby Days, provided resources and information to congressional staffers, and held several meetings with HHS Healthcare Resilience Working Group (a committee of Operation Warp Speed) to educate various federal agencies with oversight of COVID-19 strategies (e.g., CDC, FEMA, FDA, CMS, etc.). on industry challenges during the pandemic.

Advocacy alert to members of Congress on Testing (August 2021)

2021 Congressional Briefing resources:  Talking points and priorities (March 2021)

Other COVID-19 Testing Resources

UCA has worked with the CDC, state and local public health agencies to add urgent care centers to the original CDC Playbook on Vaccination Administration and related state emergency plans.  Through the early phases of the vaccine rollout to recent new guidelines on vaccine administration regarding boosters, UCA has served as a conduit of information to our members and worked to provide instructions on registration guidelines and updates from the federal government, state and local agencies  that urgent care centers.  In addition, UCA participated in key meeting with CMS regarding reimbursement rates for vaccination administration.

CDC Enrollment Information

CMS COVID-19 Vaccine Policies and Guidance

CMS Reimbursement Rate Information

State Vaccination Enrollment Plans and Contacts 

UCA has been working with the CDC and all 50 states to help identify urgent care centers that can rapidly deploy and administer the COVID-19 vaccine upon FDA approval. Each state has submitted its vaccination administration plan and contact information to the CDC.  Vaccination Task Forces led by state and local public health departments have been created for each state to administer and provide guidance on the COVID-19 vaccination. If you have any additional questions, please contact UCA's Chief Governmental Affairs Officer Kim Youngblood.

Over the past several months UCA has partnered with HHS to enroll a significant number of urgent care centers serving as mAbs infusion centers.  Since UCCs are testing and treating a record volume of patients with COVID-19, monoclonal antibody therapeutics treatments can often provide an immediate lifesaving option to combat the virus. 

mAbs Direct Order information
Therapeutics Distribution Information

Reimbursement information