17 August 2021
Earlier today, the Washington State Department of Health (DOH) released the COVID-19 Vaccination Requirement for health care workers FAQs. We are sharing this document to help our members and community make decisions and take action in compliance with state law.
While this FAQ document does not go into extensive detail about exemptions, it does answer some of the other questions we know you've been asking:
  • Per this document, even those health care providers who are providing exclusively telehealth are subject to this vaccination requirement.
  • The vaccination requirement includes any staff, employees, volunteers, or contractors who are routinely in your office, which is defined as a "health care setting." This means that you will need to ensure that your support staff is also vaccinated against COVID-19 in order to be in compliance with this proclamation.
  • Those of you who work in solo private practice are also subject to this vaccination requirement.
Both the proclamation and this FAQ document indicate that failure to comply with this requirement is considered a gross misdemeanor. The question of who will be monitoring or regulating compliance is not explicitly addressed in either the proclamation or this document, but our contact with DOH representatives indicates that it will most likely be complaint-based. (Details are still emerging, so this may change.)
We certainly recognize that the majority of questions you and your patients are asking are about which members of our communities qualify for an exemption. At the present time, there are almost no medical exemptions outside of anaphylaxis to an ingredient in the vaccine. Per the Washington State Department of Health COVID-19 Vaccine Clinical Information for Providers page: "COVID-19 vaccines should not be given to people with a known history of severe allergic reaction, such as anaphylaxis, to any ingredient or a previous dose of the COVID-19 vaccines." This guidance is aligned with the recommendations of the CDC, which also identifies a known PEG allergy as a contraindication to the mRNA vaccines, but not to COVID-19 vaccination in general. (We recommend that you read the section on "Contraindications and Precautions" here to learn more.) If you have patients who are undergoing treatment for cancer or who have a history of organ transplantation requiring on-going immunosuppressant therapy, you may consider referring those patients to their prescribing specialists (or consider consulting with other members of their health care team yourself) to help determine whether or when they should be vaccinated against COVID-19.
The religious belief exemption is a bit more complex and we encourage you to consult an attorney (and/or your employer if applicable) with any specific questions you have about utilizing this exemption for your patients or yourself.
As always, we will continue to do our best to share information as we receive it. We strive to be a resource for our members and community and we will continue to seek clarification where questions remain.