Starting October 1, the Centers for Disease Control and Prevention (CDC) will require applicants for a US green card or immigrant visa to be fully vaccinated with an approved COVID-19 vaccine, in addition to receiving all other previously required vaccines. Applicants must submit proof of COVID-19 vaccination with all required doses as part of their medical examinations, whether conducted in the US or abroad.

Here are some key points to keep in mind in anticipation of this new policy:

What is an approved vaccine?

Approved vaccines are those authorized for emergency use by the US Food and Drug Administration (FDA) or listed for emergency use by the World Health Organization (WHO). If an approved vaccine is available to the applicant in the country or state where the medical exam is conducted, the applicant must receive all the required doses and provide documentation to the panel physician or civil surgeon prior to the completion of the exam.

What is acceptable proof of vaccination?

Acceptable proof of vaccination includes an official vaccination record or copy of a medical chart. Self-reported doses without written documentation by a physician or other appropriate medical personnel will not be accepted.

Are waivers available?

Waivers will be available in some cases, including:

  • Applicants are younger than the lowest approved age limit or there is an age restriction for vaccines in the country where the exam is performed.
  • Applicants have a documented “contraindication or precaution” that indicates a potential adverse reaction to the vaccine.
  • Approved vaccines are not routinely available in the country where the applicant’s exam is conducted.
  • Applicants may request a waiver on religious or moral convictions from the US Citizenship and Immigration Services.

What steps should applicants for refugee or immigrant status take now?

Applicants should make every effort to schedule and complete their medical examination before October 1 to avoid any delays related to meeting the new vaccination requirement. Unvaccinated applicants within the US who have medical exams scheduled on or after October 1 should get vaccinated as soon as possible. Applicants outside the US unable to complete their exams before October 1 should immediately begin exploring the vaccination options in their country.

Thank You,
Mayer Brown Global Mobility & Migration

Learn more about our Global Mobility & Migration practice.

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