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Vaccine and masking requirements for healthcare workers

The following is intended as a plain language summary of rules and recommendations for the mitigation of COVID-19 and does not replace the need to follow all applicable federal, state, and local laws and regulations.

This guidance document was last updated May 10, 2023. This update includes changes to masking requirements and excludes higher education settings from the vaccination requirement. Changes are bolded for quick reference (bold headings excluded).

The City of Philadelphia issued an Emergency Regulation Governing the Control and Prevention of COVID-19 Mandating Vaccines for Healthcare Workers and In Higher Education, Healthcare, and Related Settings (“Vaccine Mandate Regulation”), which mandates vaccine for healthcare workers and in higher education, healthcare, and related settings. This mandate became effective on August 16, 2021.

Certain settings and individuals previously required to comply with the Vaccine Mandate Regulation are excluded from the vaccination requirements. These requirements are modified according to recommendations of the Philadelphia Department of Public Health (the Health Department). Institutions of Higher Education (IHE’s) are excluded from vaccination requirements unless qualifying as healthcare institutions or hosting covered healthcare workers.

As of May 10, 2023, covered healthcare workers and individuals are no longer required by City regulation to wear a mask in healthcare settings.

All symptomatic individuals must continue to test, regardless of vaccination status. See sections below on vaccination records and result reporting for further information. Any changes will be announced via traditional print and social media, posted on the Health Department’s website, and communicated in Health Action Notifications (HAN).


  • Contracting agency: Any individual or entity that contracts with a healthcare institution.
  • Fully vaccinated: Having completed at least:
    • Two doses in an initial two-dose monovalent mRNA COVID-19 vaccination, or;
    • A single dose in an initial one-dose COVID-19 vaccination approved by the FDA, or;
    • Having completed 1 bivalent or updated 2023-2024 COVID-19 vaccine dose for an individual who has not had any previous vaccination.
  • Healthcare institution: Any entity that employs or otherwise coordinates the services of covered healthcare workers at a location where in-person healthcare-related services are provided or available, and locations that are primarily retail-oriented.
  • Covered healthcare workers: An individual, including a self-employed individual, who is patient-facing at a healthcare institution where in-person healthcare-related services are provided or available to patients or clients. Patient-facing means to deliver healthcare or healthcare-related services as part of regularly performed duties or other face-to-face interactions with clients or patients as an employee, staff member, volunteer, or supervised student/intern/trainee. Individuals working exclusively in personal care or private homes with no other contacts with patients at another location where healthcare-related services are provided are excluded from this definition.
  • Healthcare-related services: In-person services provided to or available at a location, as listed below:
    • Inpatient or outpatient medicine.
    • Behavioral health.
    • Dental.
    • Nursing.
    • Assisted living.
    • Intermediate care.
    • Adult daycare.
    • Long-term care.
    • Acupuncture.
    • Audiology.
    • Hearing aid.
    • Chiropractic care.
    • Naturopathic care.
    • Occupational therapy.
    • Physical therapy.
    • Athletic training as defined by the PA Board of Medicine as the management and provision of care of injuries to a physically active person, with the direction of a licensed physician, including giving emergency care, and creating injury prevention programs for the physically active person.
    • Optometry.
    • Speech and language pathology.
    • COVID testing.
    • Vaccine clinic.
    • Blood drive.
    • School nursing.
    • Pharmaceutical.
  • Personal care home: Residences that provide shelter, meals, supervision and assistance with personal care home services, typically for older people, or people with physical, behavioral health, or cognitive disabilities who are unable to care for themselves but do not need nursing home or medical care.
  • Provider: A department-enrolled entity which provides a service.

Who is covered under the mandate

Contracting agency

A healthcare institution may delegate responsibility for obtaining vaccine status, evaluating exemptions, and implementing appropriate accommodations to a contracting agency. If delegated, the contracting agency must agree to abide by the following requirements:

  • The contracting agency agrees to perform all responsibilities of the healthcare institution as provided for in the Vaccine Mandate Regulation and this guidance.
  • The contracting agency must, at a minimum, report to the healthcare institution the following for all contract workers who perform services at the healthcare institution:
    • Percentage of contract workers that are vaccinated.
    • Percentage of contract workers with exemptions.
  • The contracting agency must make all required records available to the Health Department upon request. The healthcare institution remains responsible for assuring its contractors comply with these requirements if responsibility under the Vaccine Mandate Regulation is delegated to the contracting agency.

Healthcare institution

  • Includes contracted workers.

Covered healthcare workers

  • All covered healthcare workers performing duties in the City of Philadelphia: Individuals who are not required to be vaccinated include only those who are not patient facing, either through their direct work or the setting of their work:
    • Individuals who perform their duties completely through telework.
    • Individuals who are employed at a retail establishment that provides only incidental healthcare-related services, such as pharmacies and grocery stores.
    • Individuals who are employed by an excluded healthcare institution.
    • Individuals who do not provide healthcare or healthcare-related services to patients or clients; and do not work in a building where patients or clients receive such services, such as a medical billing specialist or appointment setter.
  • Covered healthcare workers are required to receive at least one dose of vaccine in an initial twodose vaccination series or a single dose in an initial one-dose series before beginning in-person work.


An individual may not simply opt out of vaccination. They must submit a medical or religious exemption to the healthcare institution where such individual works according to the policies set by the institution. The institution will determine if an exemption applies.

Healthcare institutions and organizations that are granting exemptions must create appropriate exemption policies to implement this regulation. Institutions may establish stricter vaccination policies for their workers, contractors, and volunteers that exceed the requirements of the Vaccine Mandate Regulation, to the extent otherwise permitted by applicable law.

A covered healthcare worker who is granted an exemption must strictly follow the conditions for exemption. Healthcare institutions are required to keep records of vaccination status of all vaccinated individuals and exemptions requested. Records must be made available to the Health Department upon request.

Self-employed covered healthcare workers must carefully document the need for exemption and ongoing compliance with conditions as set forth below under “Conditions for Exceptions.”


The Covered healthcare worker may request an exemption by submitting a certification from a licensed healthcare provider to the appropriate healthcare institution.

Medical exemptions must include a statement signed by a licensed healthcare provider that states the exemption applies to the specific individual submitting the certification because the COVID-19 vaccine is medically contraindicated for the individual. The certification must also be signed by the healthcare worker or healthcare institution worker. For the purposes of the Vaccine Mandate Regulation, a licensed healthcare provider means a physician, nurse practitioner, or physician assistant licensed by an authorized state licensing board.


The covered healthcare worker may request an exemption by submitting a signed statement in writing that the individual has a sincerely held religious belief that prevents them from receiving the COVID-19 vaccination. An institution may request the worker explain in the certification why the worker’s religious belief prevents them receiving the COVID-19 vaccine. Philosophical or moral exemptions are not permitted.


  • Testing: Screening testing is not required.
  • Masking: Masking is no longer required by the Health Department for healthcare workers, patients, or visitors in healthcare institutions.
    • Masking is at the discretion of the healthcare institution in accordance with its infection control policies and practices. See updated CDC recommendations.
    • The Health Department advises that all operators of healthcare institutions should develop and implement masking plans and guidance for staff and visitors based on the risk to certain patient populations and units as well as changes in COVID-19 and other respiratory virus activity in the community.
    • No one should be prevented or prohibited from wearing a mask at any time.
    • Healthcare workers are encouraged to mask when in a room with a patient if the patient or family request that they do so.
    • All staff in any location must continue to mask upon returning to work after a COVID-19 exposure or infection per CDC guidance.

Record keeping

Vaccination records

The institution must maintain vaccination records and exemption records must be made available to the Health Department upon request.

Vaccination records must include the following information: numbers of fully, partially, unvaccinated and vaccination status unknown staff/contractors; and numbers of staff/contractors with medical or religious exemptions. Contracting agencies are responsible for reporting vaccination status of their covered workers to the healthcare institution and must maintain all records relating to vaccination status. Please note: this information must not include any confidential information such as names, dates of birth, social security numbers, or employee identification numbers.

Result reporting

If the employer is performing rapid testing under a CLIA certificate or waiver, positive results need to be reported to the Health Department within 24 hours of result. Results can be reported directly via a REDCap Database. Please contact with any questions.

If the employer is not performing the testing, they do not need to report the results to the Health Department. The results will be reported directly to the Health Department by the lab or provider.


Beginning October 16th, 2021, the Health Department will exercise its inspection authority to review records per Chapter 6-500, Section 501 of the Philadelphia Code. These records must be made available to the Health Department upon request as dictated by Chapter 6-200, Section 202(4) of the Philadelphia Code and the August 4, 2022, AMENDMENT TO THE EMERGENCY REGULATION GOVERNING THE CONTROL AND PREVENTION OF COVID-19 MANDATING VACCINES FOR HEALTHCARE WORKERS AND IN HIGHER EDUCATION, HEALTHCARE, AND RELATED SETTINGS.

Records may be examined via a future scheduled submission calendar and/or unannounced in-person or electronic compliance audits of records by Health Department personnel. Method and timeline for unannounced audits will be determined in part by information reported to the (CDC) National Healthcare Safety Network (NHSN) system and may be required in response to complaints received against an institution. Failure to comply may result in remediation planning or immediate penalties.

These may include fines, license suspensions, and other civil remedies as provided for under Section 6-103 of The Philadelphia Code, provided that each day a violation of this Regulation continues constitutes a separate violation.



If I received a single dose shot of J & J/Janssen, am I fully vaccinated to be in compliance with this mandate?

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I received two doses of the Novavax vaccine. Am I fully vaccinated to be in compliance with the mandate?

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I have only received 1 bivalent or updated 2023-2024 vaccine. Do I need to get a second dose to be considered fully vaccinated to be in compliance with this mandate?

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I have only received 1 monovalent dose of Pfizer-BioNTech or Moderna, but never got the 2nd dose of the two-dose series. Am I fully vaccinated?

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How are you recommending healthcare institutions handle exemptions? Does our institution need to create an exception committee to review, grant, or deny exemption requests?

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What are the documents required for someone seeking a medical exemption?

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What are the documents required for someone seeking a religious exemption?

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Are at-home tests a recognized form of testing?

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What can happen if a COVID-19 vaccination card is fraudulently used or provided?

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What can happen if exemption letters are fraudulently provided?

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Is there clarification regarding what “healthcare institution” covers?

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Is there clarification regarding what “healthcare workers” covers?

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Does this mandate apply to either intermediate care facilities or rehab settings where nursing is provided and/or where health-related supports are rendered?

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Does this mandate apply to behavioral health facilities or drug and alcohol rehab settings where nursing is provided and/or where health-related supports are rendered?

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Does this mandate apply to direct care workers and direct support or direct service professionals (home healthcare workers)?

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Does this mandate apply to contract employees?

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What is the process if an employee refuses to comply?

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Who can I talk to if I have questions about this as an employee?

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Who will be monitoring the compliance?

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Who is responsible for logging vaccination and testing results? Who will be checking from the City?

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