The choice of a lawyer or other professional is an important decision and should not be based solely upon advertisements. Im speechless, said several women leaving the building. Equal Employment Opportunity Commission, Illinois Paid Leave Bill Adds New Wrinkle To Legal Patchwork, DOL Scraps Expanded Religious Carveout For Contractors, 4 Takeaways From Seattle's Groundbreaking Caste Bias Ban, High Court Turns Away A Trio Of Discrimination Battles, My Virtual Valentine: Online Rules Crucial In Pandemic Era, 2nd Circ. Since the advent of the COVID-19 vaccines early in 2021, potential religious exemptions to mandatory vaccine requirements have been a challenging legal issue and focus of debate. A letter from a priest, written on behalf of a worker seeking an exemption from the vaccine mandate. Employer Response: Employers generally should assume that a religious exemption request is based on a sincerely-held belief; however, if an employer has an objective basis for questioning either the religious nature or the sincerity of a particular belief, the employer would be justified in making a limited factual inquiry (including how the employees religious belief conflicts with the employers COVID-19 vaccine requirement) and seeking additional supporting information. u]'c'VdvqkZM*&e?YJs^AWjvW This is about public health. You are encouraged to consult with your medical professional and legal adviser. Since 2008, state law has required parents only to write a letter to their school district saying vaccines violate their religious beliefs without specifying how. No allowance will be made for regular testing as an option for those unwilling to be vaccinated. Legal experts note that many common, over-the-counter drugs, from Tylenol to Tums, have similarly used decades-old fetal cell lines. 1 Exemption based on religion is one of several reasons parents can claim to avoid giving their children vaccines in certain states. BREAKING DOWN THE PRIVACY ACT REVIEW REPORT #3: Removal of The Small White House Releases National Cybersecurity Strategy, Illinois High Court Rules Per-Scan Damages Can Be Awarded Under BIPA, Grassley-Wyden Bill Aims to Fix Broken Tax Whistleblower Law, Lessons Learned From 2022s Trade Secret Verdicts, Mass. You can opt out at any time. YouTubes privacy policy is available here and YouTubes terms of service is available here. Dirty Steel-Toe Boots, Episode 16: Investigations and the OSH Acts DOE Issues FOA for Carbon Capture Large-Scale Pilots and Carbon A Forward Look at IRAs Sweeping Impact on the EV Sector [PODCAST]. Scott Schild | sschild@syracuse.com. $#HXz&H,]48f0#ip0#pQLcd )q)!8p`gN!W!`P3;,$B@TFi%o}C?SnAqx,'b Since the two abortions occurred, one in 1973, the other in 1985, neither formal nor material cooperation is possible now, and cannot consequently justify an exemption from vaccination. Can Nonprecedential Decisions Be Relied Upon? THE CITY obtained several religious exemption requests filed by nonprofit employees contracted by the city. Meanwhile, the Omicron variant looms. endobj hXmo6+b(S@a6@qAUWm5#7NzxwD52iHK4C}L4 2 0 obj All rights reserved (About Us). For hours, loud chants from opponents disrupted the state Senate session, with protesters shouting, We do not consent, and In God we trust.. The amendments to the bill passed both houses of the state Legislature last Thursday. endstream This is a real issue.. COVID Vaccine Religious Exemption Letters Show Battle of Faith vs. Science - THE CITY Notes from clergy, obtained by THE CITY, range from citing "morality" to erroneous declarations that the vaccine causes COVID. The EEOC Guidance highlights several key points: Notice to Employer: Employees must inform their employer if they are requesting an exception to a COVID-19 vaccination requirement because of a conflict between that requirement and their sincerely-held religious beliefs, practices or observations. Current Revision Date: 02/2022 Authority or Regulation: 5 U.S.C. Undue Hardship: Pursuant to the EEOC Guidance, an employer should thoroughly consider all possible reasonable accommodations, including telework and job reassignments. Y&+"b`,$O@0x$,``$s endstream endobj startxref 0 %%EOF 237 0 obj <>stream Amtrak Pact Puts MTAs Penn Station Access Megaproject Back on Schedule, Unlicensed Pot Shops Still Selling Weed Following NYPD Shutdown Actions, Contractor Gets Rare Homicide Conviction in Death of Crushed Brooklyn Worker. You are responsible for reading, understanding and agreeing to the National Law Review's (NLRs) and the National Law Forum LLC's Terms of Use and Privacy Policy before using the National Law Review website. Expanding Regulatory Reach over Intermediaries That May Constitute How to Value Digital Assets for Donation to Charity. Over the past few years, state lawmakers have taken on the challenge of dealing with accused child predators among the ranks of teachers and educators. At this time, religious exemptions do not appear to apply to testing mandates, although Wefer thinks that will eventually be challenged in court. Our journalism needs your support. OScanlon agreed as long as the bill was changed to give privately run day care centers and schools in the state the option to accept unvaccinated children. 8:57-4.4, Immunization of Pupils in School, Medical and Religious Exemptions. This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply. Use of and/or registration on any portion of this site constitutes acceptance of our User Agreement, Privacy Policy and Cookie Statement, and Your Privacy Choices and Rights (each updated 1/26/2023). Susan K. Livio may be reached at slivio@njadvancemedia.com. As for city employees, their religious and medical exemption applications are reviewed by each agencys Equal Opportunity Commission officer and human resources staffer. She advises clients on a wide range of employment law issues including day-to-day advice and counsel on compliance with federal, state and local employment laws. White House Requires Removal of TikTok App from FDA Withdraws Proposed Rule on General Principles for Food Standards New FAQs Dramatically Expand Scope of California Labor Contractor Today is the Day Dont Miss the Employer Deadline to Report to OSHA, PTO Seeks Comments on Role of Artificial Intelligence in Inventorship. 8:57-6:15). She advises you not to use form letters you can find on the internet or to copy someone. If they reject the filing, city workers can appeal that decision to a panel composed of members from the Law Department, Department of Citywide Administrative Services, and New York City Commission on Human Rights. The Future of Stablecoins, Crypto Staking and Custody of Digital White House Climate and Environmental Justice Screening Tool. There is no exemption for drunk driving or wearing a seat belt; there should not be an exemption from a patently safe vaccine that, if not taken, puts the health and well-being of our children at risk, Senate Majority Leader Loretta Weinberg said. Any legal analysis, legislative updates or other content and links should not be construed as legal or professional advice or a substitute for such advice. For hours on Monday, loud chants from opponents disrupted the state Senate session, with protesters shouting, We do not consent, and In God we trust.. All rights reserved (About Us). On February 26 th, the Supreme Court of the United States issued a shadow docket decision that could foretell sweeping limitations for public health measures, both within and outside the COVID-19 pandemic context. While the New York and Maine cases are of limited precedential value, since they apply to a narrow set of rules applicable to healthcare workers, the implications are that courts are not necessarily requiring religious accommodations to COVID-19 vaccination mandates, where the statutes or regulations under court review do not require them. It bears emphasis, however, that the First and Second Circuits merely ruled that preliminary injunctions against enforcement of the state vaccination mandates for healthcare workers were not warranted. A countdown of the 20 most populous municipalities in New Jersey, as measured by the 2020 Census. It has declined, saying that the exemption policy has been something. The measure preserves exemptions in cases where doctors can cite medical reasons to forgo vaccines. Hundreds of FDNY members and other emergency responders packed the street outside Gracie Mansion to protest the vaccine mandate for city workers, Oct. 28, 2021. << /Pages 28 0 R /Type /Catalog >> Personal and political beliefs do not qualify employees for vaccination exemptions. The Department of Health also participates in cases involving medical accommodation requests. Staffers do not need to belong to a specific religious group but must prove they have sincerely held religious beliefs that go against the vaccine mandate. The use of aborted human life at early stage of existence for scientific research violates my faith, beliefs, and biblical values.. The employer is not required to provide the accommodation preferred by an employee if there are other possible reasonable accommodations. These letters, obtained by THE CITY, are among the thousands of the notes that clergy members have given to city workers and nonprofit staffers contracted with the city to get out of the employee vaccine mandate put in place by the de Blasio administration. The Democrat-led Assembly passed the bill 45-25, with six abstentions, but the Democrat-controlled state Senate postponed a vote because there weren't enough yes votes, according to the bill's sponsor and Senate President Steve Sweeney. Legislative Package Includes Bills to Advance Biofuels Research, PTO to Begin Issuing Electronic Patent Grants, OSHA to Expand the Use of Instance-by-Instance Penalties. Attorney Advertising Notice: Prior results do not guarantee a similar outcome. Were ready to go to war over this, state Senate President Stephen Sweeney, D-Gloucester, told reporters after Mondays voting session at the Statehouse in Trenton. OScanlon released a statement Monday night, saying he applauded the opponents for their tremendous, ultimately successful effort., The question now is what happens next." In the latest U.S. Supreme Court action on the matter, Justice Stephen Breyer rejected a filing by eight hospital staffers in Massachusetts seeking to block a vaccine mandate. Locking Tik Tok? EPA Releases Proposed Approach for Considering Cumulative Risks under Revised Colorado Privacy Act Rules Adopted for Review by Colorado AG. Given that applicable And. Some Christians claim the various COVID vaccines have a connection to abortion. Password (at least 8 characters required). 2105 DOWNLOAD THIS FORM: Choose a link below to begin downloading. There are also things you should not include in your letter. Part 1 training plans. GSA19R-22.pdf [PDF - 678 KB ] PDF versions of forms use Adobe Reader . 6 0 obj Please subscribe today to NJ.com. Dear Members of the TC Community, Last week, we wrote to you about the process for submitting proof of vaccination to fulfill the College's COVID-19 vaccine requirement for new and returning students, faculty, staff and TC housing affiliates. Accepting Cryptocurrency and Digital Asset Donations: What Charities Need to Know. Centers for Disease Control and Prevention, U.S. All told, some 12,000 municipal workers and an untold number of nonprofit employees have submitted religious or medical exemption letters, according to city records as of Nov. 11, the latest date available. Maines three interests are mutually reinforcing. << /Contents 8 0 R /MediaBox [ 0 0 612 792 ] /Parent 28 0 R /Resources << /ExtGState << /G3 21 0 R /G9 26 0 R >> /Font << /F10 27 0 R /F4 22 0 R /F6 23 0 R /F7 24 0 R /F8 25 0 R >> /ProcSet [ /PDF /Text /ImageB /ImageC /ImageI ] /XObject << /X5 7 0 R >> >> /StructParents 0 /Type /Page >> Phil Murphy's desk. Enter your details below and select your area(s) of interest to receive Law360 Employment Authority daily newsletters and section features. But the changes quickly created new problems. That aside, Gorsuch is clearly out of his depth when he, along with plaintiffs, fail to see that if there is a moral compromise, it is not on account of the vaccines connection with morally compromised cell lines but that being vaccinated constitutes formal or material cooperation with an abortion. All of these issues remain in flux and it will be very telling how, if at all, the forthcoming OSHA rule addresses these issues. Follow her on Twitter @SusanKLivio. The science is settled, she told reporters after the session. Philosophical exemption indicates that the statutory language does not restrict the exemption to purely religious or spiritual beliefs. Staffers waiting for a response on their exemptions remain on the payroll and working while other anti-vaxxers who did not file exemption requests have been put on unpaid leave. Consider then what Justice Marshall Harlan wrote for the Supreme Court in Jacobson v. Massachusetts (1905): the liberty secured by the Constitution of the United States to every person within its jurisdiction does not import an absolute right in each person to be, at all times and in all circumstances, wholly freed from restraint. Tellingly, he continued, There are manifold restraints to which every person is necessarily subject for the common good. And even more tellingly, he concluded, Real liberty for all could not exist under the operation of a principle which recognizes the right of each individual person to use his ownregardless of the injury that may be done to others.. Other federal defense agencies have rarely granted religious exemptions for other vaccines. The relative ease of the request enabled nearly 14,000 New Jersey children to get the exemption in the last school year, according to state education data. Unfortunately, those who refuse vaccination, for . "Any individual is free to exercise discretion on getting the vaccine. Weinberg stressed that no major religion opposes vaccinations. Subscribe to NJ.coms newsletters. Governor Sheila Oliver, Improving Health Through Leadership and Innovation, Resources and Tools for School and College Health Administrators, Memo about School Immunization Requirements, Local Health Department and School Audits, Antimicrobial Stewardship Recognition Program, Daycares, Schools, and Higher Education (DSH) Team, Influenza and Respiratory Illness Surveillance Reports, NJ Immunization Requirements Frequently Asked Questions, Antibody Titer for Measles, Mumps, Rubella, Health Care Providers - Mandatory Participation in the NJ Immunization Information System (NJIIS), Guidance for Implementation of Meningococal Vaccine Requirements, Cover Letter - Provisional Admission Student Tracking Form, Provisional Admission Student Tracking Form, Additional Immunization Requirements for School Attendance, Childhood and Adolescent Recommended Vaccines. Theres 9 million people in the state, he said. Sweeney said Senate leaders brought in three medical doctors to meet with lawmakers before Mondays session to argue why the bill is needed. Given that applicable federal, state and local laws generally require accommodation of an employees sincerely-held religious beliefs if they do not create an undue hardship on the employers operations, the highly personal nature of these issues in the context of vaccination mandates raises a unique set of issues. DETROIT (FOX 2) - As the COVID-19 pandemic drags on, vaccines are readily available. 2023 Advance Local Media LLC. 2021-03-25 17:02:34 -0400. JFIF C << /BitsPerComponent 8 /ColorSpace /DeviceRGB /ColorTransform 0 /Filter /DCTDecode /Height 262 /Subtype /Image /Type /XObject /Width 710 /Length 34288 >> Hundreds gathered in the courtyards outside the Statehouse again Monday as the Senate huddled hours behind closed doors to debate the bill. Free Speech Shines Bright, Illuminates Patent Owners Right to Allege California Supreme Court to Address Rounding of Employee Time. INITIAL HERE: _____ I have provided a written statement signed by me (if over age 18), or by my parent or legal guardian if a minor, explaining how the . While following these guidelines may increase the likelihood that you boss will accept your religious exemption, Frattarelli says some companies are challenging them based on your past behavior. Discrimination Attys Should Watch These 6 Arguments In Feb. 4 State-Level Policy Moves Employment Attys Should Know. The three nurses unsuccessfully argued the mandate did not give enough latitude to people who argue their religious beliefs should exempt them. For an optimal experience visit our site on another browser. His defense of exemption for religious reasons derives from First Amendment protections for the free exercise of religion. Kevin McCall is vowing to give COVID inoculation exemptions to members of his church trying to avoid vaccine mandates and is even offering the letters as an enticement so people will . Religious Exemptions: Employees who wish to apply for a religious exemption from the University vaccine requirement must provide, using this form, a description of how administration of the COVID-19 vaccine conflicts with the employee's bona fide and sincerely held religious belief or practice that precludes the employee from being Due to their effectiveness, many diseases known to have a devastating, sometimes fatal, effect on children, such as polio, were nearly eradicated in our country," Amisha Malhotra, a pediatric infectious disease expert and associate professor at Robert Wood Johnson Medical School, said in a statement Monday in support of the bill. The public hearing and voting process, however, will have to start over. The push to eliminate the long-abused religious exemption from some mandatory immunizations for public school students may be back on (the last effort . % NLR does not answer legal questions nor will we refer you to an attorney or other professional if you request such information from us. Risk is Low. Nonprofits are handling the exemption requests in varying ways. NLRB Places New Limitations on Confidentiality and Non-Disparagement Settlement Will Benefit Many Aging-Out Children in the Green Card SEC Commissioner Discusses Reform to Regulation D, Massachusetts AG Settles Enforcement Action Against Auto Lender. EXPOSED: Does a New NCLC Ex Parte Filing Expose Their True Agenda to Little Weight Given to Conclusory Expert Declaration That Repeats IPR Department of Homeland Security Provides Information Related to EB-5 PTAB: Vidal Refocuses Guidance On Fintiv Factors And Discretionary Aluminum Is Now A Hot Topic In Supply Chain And Trade. endobj Two similar cases by New York workers trying to overturn the government mandate are pending. We will pass this bill. US Executive Branch Update March 2, 2023. The material on this site may not be reproduced, distributed, transmitted, cached or otherwise used, except with the prior written permission of Advance Local. All information, data and material contained, presented, or provided here is for general information purposes only and is not to be construed as reflecting the knowledge or opinions of the publisher, and is not to be construed or intended as providing medical or legal advice. Since the advent of the COVID-19 vaccines early in 2021, potential religious exemptions to mandatory vaccine requirements have been a challenging legal issue and focus of debate. Schools, child care centers and local Mandatory Arbitration Agreements Remain Valid in California, Antitrust Practitioners Expect Activity With Climate Issues. By Friday night, NJ Advance Media reported the bill was in trouble again. People have to prove that the mandate somehow targets their religion in order to be exempt from the requirement. 5 0 obj 7 0 obj Murphy said about a new mask mandate in NJ, Tripledemic clears NJ shelves of childrens medications, Equal Employment Opportunity Policy and EEO Report. The content and links on www.NatLawReview.comare intended for general information purposes only. TRENTON, N.J. New Jersey's Assembly on Monday passed a measure to eliminate religious exemptions for vaccines for schoolchildren, but the bill stalled in the state Senate as opponents shouted so loudly they drowned out the session. Still, the memo is clear that New York priests should not provide any religious exemptions for Covid-19 vaccines. "Don't talk about science, don't talk about politics don't talk about your personal medical information," Wefer cautions. One evangelical Christian staffers religious exemption request cites the use of aborted fetal cells in some elements of vaccine testing and development. No attorney-client or confidential relationship is formed by the transmission of information between you and the National Law Review website or any of the law firms, attorneys or other professionals or organizations who include content on the National Law Review website. The results of those local challenges have been mixed. According to OHA's vaccine rules, a religious exception means "that an individual has a sincerely held religious belief that prevents the individual from receiving a COVID-19 vaccination." In . !1AQa"q2TV#7BRb$3rstu56SU%8Cc4W&Ddv 4 !1AQ"23aq#R4BS ? Employers Beware: Non-Disparagement and Confidentiality Covenants in Consultation Paper On Review of Corporate Governance Norms For A High Californias War On The Fast-Food Industry Continues. Many Catholics currently find themselves faced with a COVID vaccine mandate of one sort or another. Community Rules apply to all content you upload or otherwise submit to this site. Some have been convicted and sentenced to prison, while others have accepted plea deals for probation. 2023 Advance Local Media LLC. Each reproduction is a step away from the original stem cells, although they remain related genetically in the manner of identical twins. But last week, sponsors convinced Monmouth County Republican Declan OScanlon to vote yes. Last month, a federal appeals panel upheld New York States vaccine mandate for health care workers. That law mandates employers give their employees reasonable accommodation for their faiths. Medical and Religious Exemptions . Government agencies have a lot of leeway when it comes to enforcing a vaccine mandate, under case law. A pastor at Manhattan Baptist church wrote a letter on behalf of a congregant. One letter by a priest cites the part of the Catechism of the Catholic Church that says: God willed that man should be in the hand of his own counsel., The letter then notes the employee seeking the exemption is exercising her faculty of reason while considering Church teachings founded upon Biblical revelation.. hb```l@ 960%|nT )p+@HBJr-!>@AF Sue Collins, co-founder of the New Jersey Coalition for Vaccination Choice, said this was a victory for both religious and medical freedoms in the state. 2023, Portfolio Media, Inc. | About Employment Authority | Contact Us | Advertise with Law360 | Terms | Privacy Policy | Cookie Settings. When considering workplace safety, an employer may consider such factors includingthe nature of the employees duties, the number of employees who are vaccinated, how many employees and non-employees enter the workplace and the number of employees who will need a particular accommodation. The chances of defeating the mandate are between slim and none and slim is out of town, said Manhattan-based lawyer Jerold Levine, who focuses on civil service and gun rights cases. "Include historical information about yourself, like sacraments you've made or things that are important to you in your religion. The university administration may feel comfortable with this policy since New Jersey state law provides for exemption from vaccination on religious grounds. Medical and Religious Exemptions . Many of the people who object to the vaccine for religious reasons cite the use of aborted fetal cells in the development of the vaccines as a reason to oppose them. A planned vote on an earlier version which would have applied to all the states day care centers and schools fell apart amid protests on Dec. 12. "It Ain't Over 'Til It's Over" - Use Of A PTO Introduces Trademark Decisions and Proceedings Search Tool, FDA Issues Draft Guidance on Labeling of Plant-Based Milk Alternatives, Government Wins $43 Million Verdict in False Claims Act Case, BETO Will Host March 23 Listening Session on Next Billion-Ton Report. The administration might also be inclined to defend its exemption policy by invoking the opinion of Supreme Court Justice Neil Gorsuch, who dissented in the Courts recent decision not to stay the State of Maines policy for mandatory vaccination for healthcare workers, providing an exemption on medical but not religious grounds. We're not done with it. "Write it sincerely," Wefer advises. The former requires plaintiffs to be a party to the abortion. On October 25, 2021, the EEOC issued updated and expanded technical guidance (the EEOC Guidance) concerning how Title VII of the Civil Rights Act of 1964, as amended applies when an employee requests a religious exemption to employer COVID-19 vaccination requirements. The Court's ruling in the case, Gateway City Church v. Newsom, blocked a county-level ban on church services . Over 94% of the close to 400,000 city workers were vaccinated as of early November. By submitting your email, you agree to our Terms and Privacy Notice. The COVID-19 vaccine mandate presents an opportunity to affirm the Army's commitment to soldiers' religious liberty and spiritual readiness. Nor, for that matter, is exemption justified because of a connection between the vaccines and cell lines derived from aborted fetuses. Last week, the U.S. Supreme Court, on a 6-3 vote, refused to review the First Circuits ruling. Religious Exemption : an exemption to the immunization requirements set forth by the State of New Jersey based on my religious objections as pursuant to N.J.A.C. Some, though, are opting to accept every application in part because they dont have the resources for potential court battles, according to Michelle Jackson, executive director for the Human Services Council, which represents 170 nonprofits in New York City. Justice and Commerce Departments Announce Creation of Disruptive United States Department of Justice (DOJ), Biden Executive Order 14091 Strengthens Equity for Federal Agencies. New Jersey employers can make employees get inoculated against COVID-19 before setting foot on a worksite provided they allow certain exemptions, the state said in recent guidance that lays out a legal road map for businesses that want to adopt a mandatory vaccination policy. His office declined to say what he would do with the bill. Opponents argue that the measure infringes on their rights as parents to decide what's best for their children. H-2B Cap for Fiscal Year 2023 Is Met: A Supplemental Cap Increase As COVID-19 Emergency Waivers End, DEA Proposes to Expand Tele- How Employers Need to Prepare for the End of the COVID Public Health USPTO To Transition To Electronically Granted Patents In April 2023, Reductions in Force: Some High-Level Issues To Consider, CMS Streamlines Stark Law Self-Referral Disclosure Protocol (SRDP), The Alice Eligibility Two-Step Dance Continues, FTC is Talking Trash and Zeroing-in on Recyclable Claims, FTC Hosts Forum on Proposed Rule to Ban Noncompete Clauses. Its about protecting people.. Concern about the vaccination rate grew last year after an outbreak of measles was reported in Rockland County, N.Y. and New York City, where more than 70 percent of the 1,282 cases in the nation occurred, according to the U.S. Centers for Disease Control and Prevention. endobj Any reliance on Gorsuch here would be ill-advised. Another letter, by a Manhattan-based Baptist pastor, says the church ministry does not support the mandate and erroneously stated that the vaccines ingredients creates possibility of long-term adverse effects such as COVID-19.. The Rev. 0!_1k{8S mmqWr->yAUf2 {|Y':N Gw2RB'TDt*%FJM(a*s]T[BveHN%562;ssiAu' @@bjHm#J(=s! New Jersey School Immunization Requirements & Updates Webinar New Jersey Democrats think it's possible. Normally, those who wish not to get vaccinated can request a religious exemption. The National Law Review is a free to use, no-log in database of legal and business articles. Attorney Peter Frattarelli with Archer & Greiner P.C. This is about public health. Those staffers whose names were redacted are also covered by the vaccine mandate. Some state and local mandates, including New York States emergency regulation requiring most healthcare workers to be vaccinated as a condition of working on-site and interfacing with patients and co-workers, have been challenged through lawsuits due to the absence of religious exemptions to the mandatory vaccine. Immunizations are regularly monitored and undergo surveillance to ensure safety. Fetal cells are not present in the actual vaccines. This is a specious argument . Follow us on Twitter @NJ_Opinion and on Facebook at NJ.com Opinion. Life is precious and the sanctity of life is at the core of all divine purpose, the missive states. endstream The National Law Review - National Law Forum LLC 3 Grant Square #141 Hinsdale, IL 60521 Telephone (708) 357-3317 ortollfree(877)357-3317. endobj Federally Recognized Holidays, Employer Considerations for DOLs New AEWR Rule. Specifically, the Department received questions on what should be included in the medical
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