COVID-19 vaccination exemptions: what’s the criteria?

A person sits at their desk in front of their laptop and Australian passport, holding a phone which shows their COVID-19 digital certificate.

For the fully vaccinated, life in NSW is – thankfully – returning to some sort of new normality. But for those who are hesitant or opposed to vaccination and haven’t yet had a double dose, a small number of restrictions may still apply.

Doctors may face pressure from some patients to issue certificates exempting them from COVID-19 vaccination.

As a doctor in this situation, it is important to remember the criteria for vaccination exemption are limited to a very specific set of medical contraindications.

From 25 February 2022, the Australian Immunisation Register immunisation medical exemption form (IM011) is the only approved form in NSW to provide evidence of a medical contraindication to COVID-19 vaccination.

Having a good understanding of the criteria for COVID-19 vaccination exemption – and being prepared for some difficult patient consults – is the key to successfully managing this challenge.

Temporary medical exemptions

Vaccinations may be temporarily deferred for individuals with some acute major medical conditions for a maximum of 6 months.

These acute major medical conditions can include:

  • undergoing major surgery or hospital admission for a serious illness, or
  • infection with SARS-CoV-2 within the last 3 months, confirmed via polymerase chain reaction (PCR) or a rapid antigen test (RAT) that has been reported to the relevant jurisdiction reporting system where possible. The next scheduled dose should be given as soon as possible after a maximum 4-month deferral following confirmed infection.

If a patient requests a temporary vaccination exemption on the grounds of a past COVID-19 infection, Dr Martine Walker, medical advisor at the Medical Council, suggests asking for the patient’s consent to contact the relevant lab, testing centre, or jurisdiction reporting system to get evidence of the infection. Asking to see documentation that proves their diagnosis would also be reasonable in the circumstances. The ATAGI Expanded Guidance has more information on temporary vaccination exemptions.

Being pregnant or experiencing chronic symptoms following COVID-19 ('Long COVID') are not valid grounds for exemption from receiving COVID-19 vaccines, but these circumstances do warrant a clinical discussion with the patient.

COVID-19 vaccine medical contraindication

For all brands of COVID-19 vaccine available for use in Australia (Pfizer, Moderna, AstraZeneca, and Novavax), a patient who has had a serious adverse reaction (such as anaphylaxis) to the first dose has a medical contraindication to receiving a second dose of COVID-19 vaccine made with that vaccine platform. 

Who can be exempted from COVID-19 vaccination?

In order to be exempted from having a COVID-19 vaccination, a patient must have medical contraindications to all available brands of the vaccine.

If a patient has a medical contraindication to one brand of COVID-19 vaccine, they will most likely be able to receive an alternate brand. For this reason, medical exemptions from COVID-19 vaccination are extremely rare.

‘Allergy and anaphylaxis have been confused in the public health messages,’ says Graeme Stewart, clinical immunologist at the Westmead Institute for Medical Research and Clinical Professor of Medicine at the University of Sydney.

‘Twenty percent of Australians suffer from an allergy of some sort… [but] are not at risk of anaphylaxis or severe allergic reaction to these vaccines.’

For the smaller percentage of Australians who have a history of anaphylaxis or an allergic reaction to a component of a COVID-19 vaccine, they are still likely to be able to receive a COVID-19 vaccine safely after being assessed.

Change the conversation

Some patients may seek an exemption from you without medical grounds. These conversations can be quite confronting.

Dr Karen Price, President of the Royal Australian College of General Practitioners (RACGP) says ‘In these instances, it’s important to have a discussion with the patient and try to get to the bottom of their concerns and explain the benefits of vaccination for them and their unique situation. While it may be a challenging process, GPs are in a great position to support patients who are vaccine hesitant and encourage vaccine uptake.’

If a patient comes to you aggressively demanding a vaccination exemption without fulfilling the medical criteria for it, try to deescalate their aggressive behaviours.

You can do this by:

  • listening to the patient attentively,
  • making the interaction patient-centred,
  • explaining that you can’t give exemptions without evidence of genuine medical contraindications, and
  • using the Australian Immunisation Register (AIR) immunisation medical exemption form (IM011) as a checklist tool to demonstrate that the patient does not have the medical grounds for exemption.

Talking through the patient’s fears and anxieties about the COVID-19 vaccines can give you an opportunity to correct any misinformation that is influencing their vaccine hesitancy.

By certifying medical contraindications responsibly, you are protecting the wellbeing of your patients and the community at large.

More information

If a patient has a medical contraindication to one brand of COVID-19 vaccine, they will most likely be able to receive an alternate brand. For this reason, medical exemptions from COVID-19 vaccination are extremely rare.