The Centers for Disease Control and Prevention (CDC) will soon require green card and immigrant visa applicants to be vaccinated against COVID-19.

Key Points:

  • Beginning Oct. 1, applicants for lawful permanent residence will be required to provide documentation of COVID-19 vaccination before the completion of their medical exam.
  • Applicants will be required to provide either an official vaccination record or a copy of a medical chart with entries from a physician or other appropriate medical personnel showing that the applicant has received the complete COVID-19 vaccination series.
  • Waivers will be available to applicants who are “not age-appropriate” to receive a vaccination; have a “contraindication or precaution” indicating that a person might have an adverse reaction to the vaccination; or are seen by a civil surgeon or panel physician in a jurisdiction where the vaccinations are “not routinely available.” Applicants will also be able to request a waiver from U.S. Citizenship and Immigration Services (USCIS) on moral or religious grounds.
  • Previous COVID-19 infections or laboratory tests showing immunity will not be permissible bases for a vaccination waiver.
  • USCIS has not yet issued guidance or specific instructions on the new requirement.

BAL Analysis: BAL continues to review CDC guidance on the new requirement and will provide additional information ahead of the Oct. 1 implementation date.

This alert has been provided by the BAL U.S. Practice group. For additional information, please contact

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