DHSC releases vaccine exemption guidance

September 16, 2021

Today is the last date for care home workers to get their first dose of the COVID-19 vaccine, so they are fully vaccinated by the time the compulsory vaccines regulations come into force on the 11th of November. After the 11th November, anyone working or volunteering in a care home for older people will need to be fully vaccinated, unless exempt.

Vic Rayner OBE, CEO of the National Care Forum – the leading association for the not for profit care sector said, ‘The pressure on social care employers in relation to the policy to mandate vaccination in care home staff remains relentless and they are working hard to implement this policy as fairly as possible. The updated advice on 15th September from the DHSC on how to manage the process for those staff who believe they are medically exempt to self-certify to this effect has just complicated an already difficult situation for employers and their staff.

‘The current situation facing the social care workforce is like nothing seen before, with many seeing an increase in staff exits and experiencing significant difficulties to attract new staff and retain existing staff. Given that the government is now consulting on widening the policy to cover all frontline health and care staff, they should delay the date of 11th November for the go–live of this policy in care homes and align the implementation dates across the whole health and care sector.’

The Department of Health and Social Care (DHSC) has confirmed that staff asserting a medical exemption can self-certify that they meet the medical exemption criteria and has provided template forms for staff to use.

This is a temporary process while the NHS Covid Pass system is launched. When that goes live, care workers will need to apply for a formal medical exemption through that system and their asserted medical exemption will be subject to clinical review.

Self-certification will expire 12 weeks after the NHS Covid Pass system is launched.

Who is exempt?

While this list is not exhaustive, examples of medical exemptions from COVID-19 vaccination could include individuals:

  • Receiving end-of-life care where vaccination is not in the individual’s interests.
  • With learning disabilities or autistic individuals, or with a combination of impairments that result in the same distress, who find vaccination and testing distressing because of their condition and cannot be achieved through reasonable adjustments such as the provision of an accessible environment.
  • With medical contraindications to the vaccines such as severe allergy to all COVID-19 vaccines or their constituents.
  • Who have had adverse reactions to the first dose (e.g. myocarditis).

Time-limited exemptions will also be available for those with short-term medical conditions (e.g. people receiving hospital care or receiving medication that may interact with the vaccination). A time-limited exemption is also available for pregnant women should they choose to take it.

Exemptions for conditions listed in section 4.4 (special warnings and precautions for use) in the Summary of Product Characteristics for each of the approved COVID-19 vaccines (Pfizer, AstraZeneca, and Moderna) may also be considered.

Individuals who have received a COVID-19 vaccination abroad can also self-certify as medically exempt. This is because it is not clinically appropriate for them to be vaccinated in the UK if they have already received a partial or full course of vaccination overseas. The DHSC has published exemption forms for completion.

Visit the Government website for the latest updates on the vaccine exemption guidance.


The Department of Health and Social Care (DHSC) published its autumn and winter COVID-19 plan this week. Find out more.

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