• COVID-19 Vaccine Mandates and Exemptions

    Updated November 15, 2021

    OSHA, CMS Issue New Health Care Worker Vaccination Requirements

    A new emergency regulation requires COVID-19 vaccination of eligible staff at health care facilities that participate in the Medicare and Medicaid programs. Staff must be fully vaccinated by Jan. 4, 2022. 

    Information on Mandates—What We Know So Far

    On Nov. 4, the Biden Administration announced the details of two policies to help fight COVID-19 by expanding vaccination requirements, which will affect health care workers in certain settings.

    • Occupational Safety and Health Administration (OSHA): Requires employers with 100 or more employees to ensure that each of their workers is fully vaccinated or undergoes weekly testing for COVID-19. The date of effect is January 4, 2022, however, this date may not be final pending review of several lawsuits. There is a temporary stay issued by the U.S. Court of Appeals for the Fifth Circuit.
    • Centers for Medicare & Medicaid Services (CMS): Health care workers at certain facilities that participate in Medicare and Medicaid be fully vaccinated. (See the CMS Omnibus COVID-19 Health Care Staff Vaccination Interim Final Rule.)

    The FPM Blog, New OSHA and CMS rules outline vaccination requirements for health care workers, examines what practices need to know about the policies. 

    The AAFP supported the call for vaccine mandates for all workers in health care and long-term care facilities.

    Vaccine Exemptions

    The AAFP has reviewed and approved all of the CDC’s ACIP recommendations related to COVID-19 vaccines. AAFP supports the vaccines as safe and effective tools to end the pandemic and encourages all individuals to get vaccinated.

    As outlined in the Immunization Exemptions policy, with the exception of policies allowing for refusal due to a documented allergy or medical contraindication, the AAFP does not support immunization exemption policies.


    The CDC’s current interim clinical considerations lists contraindications for COVID-19 vaccines. View a brief summary sheet.


    Individuals with the following characteristics can receive and are recommended to receive a vaccine. However, certain factors should prompt a risk assessment and potential referral to allergist/specialist.

    • Immediate allergic reaction to any other vaccine or injectable therapy (i.e., intramuscular, intravenous, or subcutaneous vaccines or therapies [excluding subcutaneous immunotherapy for allergies, i.e., “allergy shots”])
    • People with a contraindication to one type of vaccine have a precaution to the other type


    Please note that pregnancy/desiring pregnancy are not considered contraindications. The CDC, AAFP, ACOG, and others strongly recommend individuals who are pregnant or lactating to get vaccinated against COVID-19. Data have demonstrated that the vaccines are effective and safe for people who are considering pregnancy, are pregnant, or recently pregnant. Vaccination provides protection for the parent and baby against major issues seen after infection with COVID-19.