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Federal government issues guidance on COVID-19 vaccine religious exemptions

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by Christine Rousselle

Washington D.C., Oct 6, 2021 / 10:40 am

New guidance on issuing COVID-19 vaccine religious exemptions for federal employees insufficiently treats the matter of conscience, one Catholic bioethicist told CNA.

Federal employees are now required to be fully vaccinated against COVID-19 by Nov. 22, 2021. Guidance for federal agencies from the Office of Personnel Management, released on Monday, Oct. 4, states that employees requesting a religious exemption to the mandate “must first establish that [their] refusal to be vaccinated is based upon a sincere belief that is religious in nature.”

A template for religious exemptions includes a seven-part form for employees to fill out, asking a series of questions about employees’ religious-based objection to receiving a COVID-19 vaccine.

However, religious exemptions should be “liberally available” for employees, said Fr. Tadeusz Pacholczyk, Ph.D., the director of education at The National Catholic Bioethics Center, in an interview with CNA. Otherwise, the vaccine mandates “can easily become intrusive, blunt instruments that end up violating personal liberties,” he said.

Many of the questions about religious exemptions in the federal guidance are “largely irrelevant to assessing whether someone has conscience concerns about being vaccinated,” he said.

The template provides questions for federal agencies, such as why an employee is opposed to receiving a COVID-19 vaccine. Other questions include the length of time an employee held their religious beliefs that support their objection, their adult vaccine history, other medicines they have avoided due to religious beliefs, and why receiving a COVID-19 vaccine would “substantially burden” their religious practice.

Pacholczyk said that questions about a “substantial burden” on one’s faith or how long they have objected to COVID-19 vaccines are “not, per se, of importance.”

Instead, the important point is “whether someone manifests a current conviction of conscience that they do not wish to be vaccinated,” he said.

“Simply conveying this personal point of resolve, whether in written or even oral form, and even in the absence of revealing the reasons, ought to provide the needed basis for the granting of a conscience exemption.”

Pacholczyk told CNA that it would be an error to presume that “one size always fits all” when it comes to vaccinations.

“Decisions about medical interventions properly belong in the hands of the individual patient, who can make an assessment that corresponds to his or her on-the-ground situation much more fully and meaningfully than any federal agency can do,” he said. “The principle of subsidiarity reminds us that one should not withdraw those decisions or choices that rightly belong to individuals or smaller groups and assign them to a higher authority except unless strictly necessary.”

People who refuse the COVID-19 vaccine, or any vaccine, however, should comply with other mitigation efforts to prevent the spread of disease, he said.

“Those who decline vaccinations, of course, may reasonably be expected, and even obligated, to choose other effective precautions to help limit the spread of pathogens when pandemics arise,” he said.

According to the federal guidance on COVID-19 vaccine religious exemptions, “A refusal to be vaccinated does not qualify for an exception if it is based upon personal preference, concerns about the possible effects of the vaccine, or political opinions.”

“The purpose of this form is to determine whether you may be eligible for an exception,” says the religious exemption template. “To be eligible for a possible exception, you must first establish that your refusal to be vaccinated is based upon a sincere belief that is religious in nature.”

The guidance adds that the government “is committed to respecting the important legal protections for religious liberty.”

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