Medical exemptions from requirements relating to COVID-19 vaccination: guidance note for maternity services



Classification: Official

Publication approval reference: C1438

18 October 2021 Version 1

This guidance is intended to support maternity services to comply with the policy on the clinical review and verification of exemptions from COVID-status certification.

Trusts with maternity services are requested to note the guidance below and, in particular, recommended actions set out in paragraph 9.

About COVID-status certification and medical exemptions

1. As part of government policy, individuals are required to prove their vaccination status to:

  • work or volunteer in a CQC-regulated care home from 11 November 2021
  • be exempt from self-isolating for 10 days if they are a close contact of a confirmed COVID-19 case
  • be exempt from self-isolation and completing a Day 8 test if travelling from an amber-list country
  • enter a venue in England that requires the NHS COVID Pass as a condition of entry.

An individual will only need to apply for an exemption once, which can be applied across cases where exemptions can be used.

2. Medical exemptions for COVID-status certification are required to ensure that certification does not exclude, or impose a disproportionate burden on, individuals who have reasonable grounds not be vaccinated (and in some cases, also tested).

3. There are a number of grounds for requesting an exemption: for example, people with medical contra-indications to the vaccines. While vaccination in pregnancy continues to be recommended by the JCVI, the Green Book, RCOG, RCM and the UK Teratology Service, pregnant women are eligible to request short-term medical exemptions from vaccination. The Green Book advises that pregnant women should discuss the risks and benefits of vaccination with a trusted clinician and make an informed choice about whether to proceed with vaccination or not.

4. The medical exemptions process was launched on 1 October. Individuals can request an application form through the NHS COVID Pass service on 119.

Role of midwives/maternity services

5. While midwives, obstetricians and GPs should continue to recommend the vaccine for pregnant women (at any gestation), the option of a time-limited exemption for pregnant women who express concerns surrounding the vaccine after counselling is available.

6. In general, exemption requests must be confirmed by a doctor or clinician, before being granted. The majority of pregnant women will not need their application to be clinically reviewed as they will be able to use the MAT B1 certificate to demonstrate their exemption rather than the confirmation letter or NHS COVID Pass. However, without a MAT B1 – or those concerned with showing it – they will need to have their exemption request confirmed by a midwife, obstetrician or GP.

7. On their exemption application form, the individual will state the name of their midwife or maternity service at which they are booked – or their GP if they have not yet booked at a maternity service. They will then take the form with them to an appointment to have it verified.~

8. For each exemption request, maternity services are asked to record the outcome of this request in the Summary Care Record application (SCRa) within 10 working days of receiving the completed form from the individual. The expiry date for an exemption for pregnant women should be 16 weeks post-partum, to allow women to acquire two doses of the vaccine after birth (plus four weeks). Individuals will automatically be notified whether their exemption application was successful, and midwives do not need to issue this.

9. All trusts with maternity services are asked to put in place two measures to support vaccination exemption requests where they are made:

  • Trusts should ensure that all midwives and obstetricians are aware that they may be asked by women to endorse exemption requests, and how these should be dealt with; and
  • Directors of nursing should put in place a process for verified exemption requests to be collated and processed in SCRa. Department of Health and Social Care guidance requests that these are processed within 10 working days of receipt. For efficiency, and to minimise burden on midwives, requests should be processed in batch by designated administrators in the trust with access to SCRa. To ensure appropriate usage, NHS Digital intends in coming weeks to restrict access to the exemptions form to those with ‘B0264’ and ‘B0380’ activity codes in SCRa. Trust IT departments will be able to support the granting of these activity codes. Directors of nursing are therefore requested to identify two administrative members of staff to receive these permissions as soon as possible. For further information please see:

Clinical guidance for use with women requesting exemptions

10. COVID vaccination in pregnancy is recommended by the JCVI, the Green Book, the Royal College of Obstetricians, Royal College of Midwives and the UK Tetralogy Service. Although clinical trials on the use of COVID-19 vaccines during pregnancy are not advanced, the available data from over 160,000 vaccinations in pregnancy in the US, and 90,000 in England and Scotland, do not indicate any harm to the foetus or infant. JCVI has therefore advised that women who are pregnant should be offered vaccination at the same time as non-pregnant women, based on their age and clinical risk group.

11. The Green Book has advised that pregnant women should be offered COVID-19 vaccination on the balance of benefits and risks (as pregnant women are at risk of direct and indirect COVID-19 complications, including pre-term birth). In line with the NHS guidance, midwives, obstetricians and GPs should seek to discuss the risks and benefits of vaccination with the woman. For the latest advice, please see the:

12. While obstetricians, midwives and GPs should continue to clearly recommend the vaccine for pregnant women (at any gestation), the option of a time-limited exemption for pregnant women who express concerns surrounding the vaccine after counselling is available.

13. Breastfeeding women and those trying to become pregnant would not be considered exempt (unless there are alternative indications for exemption).