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United States Citizenship and Immigration Services (USCIS) recently announced that, effective October 1, 2021, applicants for permanent residence (i.e., green card applicants) who are “subject to the immigration medical examination must be fully vaccinated against COVID-19 before the civil surgeon can complete … [the] examination and sign Form I-693, Report of Medical Examination and Vaccination Record.” USCIS stated that this requirement “applies prospectively to all Forms I-693 signed by the civil surgeons” on or after October 1, 2021. USCIS also stated that it is revising the Form I-693 and its instructions to include the vaccination requirement.

The updated USCIS policy guidance follows the U.S. Centers for Disease Control and Prevention’s (CDC) August 17, 2021, update to the Technical Instructions for Civil Surgeons. The CDC update required applicants subject to the immigration medical examination to “complete the COVID-19 vaccine series [in addition to the other routinely required vaccines] and provide documentation of vaccination to the civil surgeon in person before completion of the medical examination.”

Applicants seeking to adjust their immigration status within the United States, as well as applicants applying for immigrant visas at U.S. embassies and consulates abroad, are subject to this requirement. To demonstrate they have completed the vaccination series, applicants may present their official vaccination records or copies of their medical charts showing that they have been vaccinated against COVID-19. The CDC stated in its guidance that “self-reported vaccine doses” will not be accepted unless they are confirmed by a doctor or other medical professional with “written documentation.” The CDC also noted that the COVID-19 vaccines manufactured by Pfizer-BioNTech, Moderna, and Janssen (Johnson & Johnson) are all acceptable.

USCIS stated that it “may grant blanket waivers” of the new vaccination requirement “if the COVID-19 vaccine is:

  • Not age-appropriate;
  • Contraindicated due to a medical condition;
  • Not routinely available where the civil surgeon practices; or
  • Limited in supply and would cause significant delay for the applicant to receive the vaccination.”

USCIS also stated that “[i]ndividuals may also apply for individual waivers based on religious beliefs or moral convictions by submitting Form I-601, Application for Waiver of Grounds of Inadmissibility.”

Ogletree Deakins’ Immigration Practice Group will continue to monitor developments with respect to these and other policy changes and will post updates on the Immigration blog and in the firm’s Coronavirus (COVID-19) Resource Center as additional information becomes available. Important information for employers is also available via the firm’s webinar and podcast programs.

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