Vaccinations: Responding to Religious Exemption Requests from Attendees

Some states are beginning to require that school and nursing home employees show proof of COVID-19 vaccinations. Many employers, on their own, also are evaluating what their policies will be.

There are a couple of ways an employee can be exempt from mandatory vaccines in the workplace or request a reasonable accommodation: if they have a documented medical reason or if they have sincerely held religious beliefs or practices that prevent them from being vaccinated.

An employer can request that the employee provide additional supporting information if the employer has an objective reason for questioning the religious nature or genuineness of the employee’s particular belief, practice, or observance.

Although a letter from a church generally should not be required, you may be asked by an attendee to write a letter to their employer as supporting documentation or to sign off on a religious objection to immunizations waiver form. Before you do so consider this important question: Does your church have sincerely held beliefs against vaccines or immunizations?

Yes?

If the answer is yes—that your ministry does have sincerely held beliefs against vaccinations or immunizations—then your ministry can stand behind your pastor or leadership providing that supporting information.

No?

If the answer is no, your church does not have sincerely held beliefs against vaccinations or immunizations, consider the following:

1. You can decline. You’re not required to write a letter or to sign a waiver for someone whose objection is based solely on his or her personal beliefs or convictions. And when an employer asks for additional supporting information, it does not mean that the employee needs a letter from the church. Religious exemptions are based on the employee’s religious beliefs and not those of a church or other religious institution.
    
2. Providing a letter from a church leader may not have legal ramifications in this situation, but it could give the false impression that your church does have beliefs against vaccinations.

More resources

Brotherhood Mutual has developed risk management resources to assist religious organizations with commonly asked questions about the COVID-19 vaccine in the context of ministry.

• COVID-19 Vaccine Basics
• Can ministry employers require the COVID-19 vaccine?

• What You Should Know About COVID-19 and the ADA, the Rehabilitation Act, and Other EEO Laws – EEOC 

Posted August 2021

The information provided in this article is intended to be helpful, but it does not constitute legal advice and is not a substitute for the advice from a licensed attorney in your area. We strongly encourage you to regularly consult with a local attorney as part of your risk management program.