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Vaccinations and the Religious Exemption

  • Isaac Mamaysky
  • Jun 2
  • 6 min read

As we gear up for another season, questions about vaccination policies are becoming more urgent, especially amid recent measles outbreaks across the country. Given the close, communal nature of camp life, many operators are asking: Can we require campers and staff to be vaccinated? Are we required to accept religious exemptions? And, most importantly, what does the law actually say?


While schools are the most commonly cited reference point for vaccine mandates, the legal framework for camps is often less defined, more state-specific, and subject to gray areas. Some states (like New Jersey) explicitly extend school vaccine exemption rules to campers at camps, while other states (such as Pennsylvania) are silent on this topic and arguably have no requirement for camps to accept religious exemptions.


For staff, the governing framework is Title VII of the Civil Rights Act, which applies to most camps and requires employers to provide reasonable accommodations for religious beliefs unless doing so would create an undue hardship. This is discussed in more detail below.


This article unpacks the legal landscape surrounding religious vaccine exemptions in both the camper and staff context.


To understand the landscape of vaccine exemptions for camps, let's begin with schools.


Every state requires certain vaccinations for children attending public school, and every state allows exemptions for students who cannot be vaccinated for medical reasons. In addition, most states also allow nonmedical exemptions based on religious or personal beliefs. Here is the lay of the land from the National Conference of State Legislatures:


All 50 states and Washington D.C. have laws requiring certain vaccines for students to attend school. . . . All states allow exemptions from school immunization requirements for children who are unable to receive vaccines for medical reasons. State laws vary regarding non-medical exemptions, for religious or personal [philosophical] reasons.
Thirty states and Washington D.C. allow exemptions for people who have religious objections to immunizations. Thirteen states allow exemptions for either religious or personal reasons. Two states, Louisiana and Minnesota, do not specify whether the non-medical exemption must be for religious or personal reasons. Five states do not allow any type of non-medical exemption.

For an overview of which states allow religious and philosophical exemptions in schools, click here.


What about summer camps?


In an April 2025 letter to camp operators, the New York Department of Health “strongly recommended” that all camp staff and campers be fully immunized. The Department of Health noted that the prolonged close contact of individuals at camp can promote the spread of vaccine-preventable diseases.


“Within the last twenty years,” the letter explains, “there have been at least three mumps outbreaks that began in summer camps in New York State; one of these outbreaks resulted in more than 3,500 cases of mumps. Another outbreak involved measles among multiple camp staff.”


The Department of Health warns: "To date, in 2025, there have been more measles cases in the United States than there have been in all of 2024. Through April 10, 2025, there have been over 700 confirmed cases of measles in 24 states, including two pediatric deaths."


In light of heightened risks, can camps turn away unvaccinated kids? Or are they bound to honor religious exemptions like so many schools?


Camps are often misunderstood and/or ignored by state legislatures, and the laws concerning camps and vaccination requirements are sometimes unclear. To understand the challenge, let’s take Pennsylvania as an example.


The words “immunization” and “vaccination” don’t appear in Pennsylvania’s camp code. The camp code’s silence could mean that camps are free to make their own determination regarding vaccination policies.


Pennsylvania does mandate a religious exemption for immunizations in “child care group settings,” which are defined as “premises in which care is provided at any one time to four or more children, unrelated to the operator.” (Read statute here.) While at first glance overnight camps fall within that definition, overnight camps are regulated and licensed separately from childcare centers. Also, the statute explicitly does not apply to “Children attending kindergarten, elementary school or a higher school who are 5 years of age or older.” While the statute might arguably apply to day camps, it doesn’t apply to overnight camps, where the youngest campers are older than 5.


According to the statute, kids over the age of 5 are subject to a different Pennsylvania law, which addresses immunizations in schools. In Pennsylvania schools (both public and private), students can be exempt from vaccination requirements under medical and religious grounds (read statute here). However, the statute specifically says: "This subchapter affects public, private and parochial schools, including kindergartens, special education classes, home education programs and vocational classes in this Commonwealth." The definition of “schools” doesn’t include camps, and camps are not mentioned in the statute.


So, in Pennsylvania, there is no law—at least none that I have found—requiring camps to accept religious exemptions from campers. One reasonable interpretation of this silence is that the state does not require camps to accept religious vaccine exemptions.


Of course, Pennsylvania is just one example, and some states take a more prescriptive approach—requiring camps to honor religious exemptions in the same way schools must. Consider New Jersey.


Under the New Jersey Youth Camp Standards, “The youth camp shall adhere to the requirements established [for schools] regarding religious exemptions for campers from immunization.” As the New Jersey Department of Health explains, “[the law] provides an exemption from mandatory immunization for a child [when parents provide a] signed statement requesting a religious exemption from the immunization. . . . Religious exemptions extend to private, parochial, and public institutions.”


However, New Jersey law does recognize the heightened risk of transmission in camp settings and grants camps discretion in emergencies: “The camp director or health director may exclude from the youth camp those children with religious exemptions . . . during a vaccine-preventable disease outbreak or threatened outbreak as determined by the Commissioner.”


The contrast between Pennsylvania and New Jersey is intended to illustrate that this is a very state-specific question.


Let’s now turn to staff vaccination policies and explore a potential legal risk involving campers.


Under federal law, employees are entitled to reasonable accommodations for their religious beliefs. Title VII of the Civil Rights Act prohibits employers from discriminating on the basis of religion and requires them to accommodate religious practices unless doing so would impose an undue hardship. This is the primary legal basis for requiring camps to consider religious exemptions for staff—but it’s important to note that Title VII applies only to employment relationships, not to campers.


Could the same reasoning apply to campers under state law?


Returning to our Pennsylvania example: Like every state, Pennsylvania prohibits discrimination on the basis of religion. That protection applies broadly to most "public accommodations," which are businesses and organizations that serve the public, including camps. In theory, a family could argue that a camp’s refusal to offer a religious exemption constitutes religious discrimination under state law.


However, the argument has limitations. Unlike Title VII, Pennsylvania’s general anti-discrimination law does not explicitly require reasonable accommodations for religious practice outside of employment or education. So while a creative legal challenge is possible, it’s not the most direct or well-supported reading of state law. That said, in the absence of clear statutory guidance, camps should be aware that a legal challenge—however novel—is at least conceivable.


What about medical exemptions under the ADA and analogous state laws?


Of course, this article is about the religious exemption, but we should note that the Americans with Disabilities Act and many state public accommodation laws require reasonable accommodations for campers with disabilities. While certain types of entities are exempt, many camps are not. So if a camper with a disability cannot be vaccinated for medical reasons, then a camp may be obligated to provide a vaccine exemption as an accommodation. To see more about ADA requirements, you can read this post: camplawandfinance.com/post/understanding-the-ada.


Conclusion


Vaccination policy is a high-stakes issue for camps—not just from a public health perspective, but also a legal one. While schools provide a familiar legal framework, the rules for camps are often less defined and vary widely from state to state. In some states, camps must follow school immunization laws, including honoring religious exemptions. In others, camps may have greater discretion to set their own policies, especially when statutes are silent or don’t expressly apply.


For staff, the obligation to consider religious exemptions is clearer under federal employment law. For campers, the legal obligations depend heavily on state statutes—and in some cases, the absence of them. Where the law is unclear, camps must balance legal risk, public health, and mission alignment.


Camps that decide to mandate vaccinations can take comfort in the fact that they are in good company. Some of the largest, most respected camps in the industry require vaccinations and do not accept religious exemptions. To the extent the law is silent on this topic, industry practices are certainly informative. Ultimately, the right approach will depend on your camp’s values, risk tolerance, and legal landscape. Understanding that landscape is the first step toward making a decision that’s both principled and defensible.

Questions? Comments?

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Contact Isaac: 212.531.5050 | imamaysky@potomaclaw.com

Mailing Address: 222 Purchase Street No. 158 | Rye, NY | 10580

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