COVID-19 | Oct. 4, 2021

Exemptions and Accommodations FAQs

Q. Should commands issue CG-3307 (P&D 41B or 41C, as applicable) to a member that has indicated they intend to seek a medical exemption or religious accommodation?
A. By now, all unvaccinated members should have received the initial CG-3307 (P&D 41A, as applicable) and should have indicated whether they will seek an exemption/accommodation. If the member indicated they will not seek an exemption/accommodation or if the member has not yet taken all steps within his/her control to seek an exemption/accommodation, the command shall issue a CG-3307 (P&D 41B or 41C, as applicable) to that member. If the member has scheduled an appointment but has not yet been seen for an exemption/accommodation and that has been verified by the command, then the command should not issue a CG-3307 (P&D 41B or 41C, as applicable) to the member. If the member has a pending or approved exemption/accommodation, the member should not be issued a 3307 (P&D 41B or 41C, as applicable).

 

Q. What are the criteria for being granted a permanent medical exemption from the COVID-19 vaccine mandate? 
A. People who have had a severe allergic reaction after a previous dose of COVID-19 vaccine, or people who are allergic to or have had a severe allergic reaction to an ingredient of the COVID-19 vaccine, can be granted a permanent medical exemption. Symptoms of severe allergy include rash, wheezing, and shortness of breath, and typically occur within 15 minutes after vaccination. 

Because these are very rare reactions to vaccination, we expect that granting of permanent exemptions will be infrequent. 

 

Q. What are the criteria for being granted a temporary medical exemption from the COVID-19 vaccine mandate? 
A. Because there are only a few specific medical criteria for granting of a temporary exemption, we expect that granting of temporary exemptions will be infrequent. 

Persons who are moderately to severely ill (with COVID-19 or any other illness) can receive a temporary exemption until they have recovered sufficiently and are no longer subject to isolation requirements. People who are acutely ill should not present for vaccination, since they might expose others to COVID-19 or other infections. Most people with minor illness without fever who are not subject to isolation should be vaccinated. 

People who are enrolled in COVID-19 related clinical studies can receive a temporary exemption until their participation in the trial is completed. The Coast Guard supports its members who voluntarily participate in important research, and does not want to interfere with the results of those studies. 

People who have been treated for COVID-19 disease with monoclonal antibodies or convalescent plasma should receive a temporary exemption until 90 days have passed since their treatment. This is to ensure the body can respond to the vaccine, without interference by antibodies included in the monoclonal and plasma treatments. People who are not sure if they received these treatments should consult with their healthcare provider. As stated previously, having had COVID-19 previously is not a criteria for a permanent medical exemption. 

 

Q. Is pregnancy a justification for a medical exemption? 
A. Pregnant and recently pregnant people with COVID-19 are at increased risk for severe illness, and preterm birth. Additionally, pregnant people with COVID-19 might be at increased risk for serious pregnancy complications and outcomes, such as life-threatening high blood pressure, bleeding disorders, and stillbirth. 

Evidence on the safety and effectiveness of COVID-19 vaccination – in both animal and human studies – indicates that the benefits of vaccination outweigh any known or potential risks of COVID-19 vaccination during pregnancy. 

Pregnant patients who have concerns about vaccination should have their concerns addressed by consultation with their prenatal care provider. If the care provider determines that it is appropriate to defer vaccination until later in pregnancy or post-pregnancy, a temporary medical exemption from vaccination until that time should be provided. 

Because of the benefits of vaccination for pregnant persons, pregnancy is not a criteria to receive a permanent medical exemption for COVID-19 vaccine. 

 

Q. Are temporary or permanent medical exemptions available for breastfeeding mothers? 
A. No. COVID-19 vaccination is recommended for all people aged 12 years and older, including people who are breastfeeding. The COVID-19 vaccines currently licensed by the Food and Drug Administration (FDA), or approved for use under an Emergency Use Authorization (EUA), cannot cause infection in either the lactating person or the infant. Recent reports have shown that the antibodies developed from mRNA COVID-19 vaccination were present in breastmilk samples. More study is needed to determine if these antibodies protect newborns and infants against SARS-CoV-2 infection. 

 

Q. What are these medical exemption recommendations based on, and where can I get more Information? 
A. These recommendations are based on information contained in Interim Clinical Considerations for Use of COVID-19 Vaccines | CDC and ACIP General Best Practice Guidelines for Immunization | CDC 

These two websites have a great deal of information about COVID-19 vaccines, and general information about vaccination. 

 

Q. What if my health care provider needs more information? 
A. The Defense Health Agency offers a clinical consultation service. Details and phone contact information are available at Clinical Consultation Services | Health.mil

 

Q. Who Can Grant Temporary or Permanent Medical Exemptions?  
A. Authority to grant temporary medical exemptions shall remain with the local military-employed or affiliated Medical Officer (MO). TRICARE Prime Remote civilian primary care managers or network providers do not have authority to grant temporary exemptions. 

COMDT (CG-1121) is now the final approval authority for any permanent medical exemption to any mandatory vaccine, in accordance with ALCOAST 315/21 and Immunization and Chemoprophylaxis for the Prevention of Infectious Diseases, COMDTINST M6230.4 (series). CG MOs may apply for a permanent medical exemption to one or more vaccines on behalf of a patient by submitting a package to their Senior Medical Executive consisting of medical documentation (including specialist consultation, if applicable) supporting the exemption and an official memo requesting the exemption. 

 

Q. My clinic doesn’t have an available appointment within routine standards for medical exemption waiver submission (seven days). What should I do? 
A. All clinics have been instructed to make appointments available and should provide an appointment within routine access to care standards (seven days). 

If a circumstance occurs where an appointment within seven days cannot be provided to support the exemption, member should ask for documentation on when the next available appointment is. If you are unable to get an appointment within seven days, please notify your next level supervisor using the documentation provided by your clinic, in addition to notifying the Regional Manager, if appropriate. 

 

Q: Are there authorized exemptions from the mandatory vaccination requirement?
A: Coast Guard policy allows, in some circumstances, medical exemptions and religious accommodations.

Under current Coast Guard policy in COMDTINST M6230.4G (a joint directive with other military services), a medical exemption includes any medical contraindication relevant to a specific vaccine or other medication, according to published recommendations from the Advisory Committee on Immunization Practices (ACIP).

COMDTINST 1000.15, Military Religious Accommodation, provides the policy and procedures for requesting a religious accommodation.

 

Q: What is the process for requesting a medical exemption?
A. Members seeking a medical exemption from the COVID-19 vaccination requirement should notify their primary health care provider, who will review and forward the request to Chief of Preventive Medicine (CG-1121) for final decision.

Members that previously had medical exemptions for COVID-19 vaccination must re-submit their request for exemption to CG-1121, via their primary health care provider.

 

Q: Will there be a religious accommodation?
A. The Coast Guard will also consider an accommodation for a sincerely held religious belief. The Office of Military Personnel Policy, COMDT (CG-133) will adjudicate requests for religious accommodation consistent with Military Religious Accommodations, COMDTINST 1000.15. Requests for a religious accommodation are granted or denied on a case-by-case basis and will be informed by input from the member’s command, medical, judge advocate, and military chaplain.

 

Q: What is the process for requesting a religious accommodation?
A. Members should notify either their chaplain or Commanding Officer (CO) of their request for a religious accommodation. The member must submit a written request to their CO pursuant to Military Religious Accommodations, COMDTINST 1000.15. COs/OICs will consult with their servicing legal office while adjudicating member requests for religious accommodation. The member will then be counseled by their CO and a military physician, and must arrange an interview with a military chaplain. Once the counseling and interview is completed and documented, the command will forward the request through the appropriate chain and the Office of Health Services (CG-112), then to the Office of Military Personnel Policy (CG-133) for final decision.

 

Q. If Commanders, Commanding Officers, or Officers in Charge do not endorse a member’s request for a religious accommodation, how do they indicate this intent on a member’s request memo?
A: In accordance with the Correspondence Manual (COMDTINST M5216.4 (series)), Commanders, Commanding Officers, and Officers in Charge may annotate a “recommend denial” or “forwarded without endorsement” along with their signature. A signature on the “Thru” line without comment indicates a favorable endorsement of the request. They may alternatively provide a separate-page endorsement that more fully explains their recommended approval or disapproval.

If a command has endorsed a member’s religious accommodation request with a signature endorsement, and the intent was not to favorably endorse the request, the command may update the record. Contact your servicing legal office for guidance.