COVID-19
Fact Sheet
COVID-19 Vaccination: State Minor Consent
Requirements
Pfizer-BioNTech’s COVID-19 vaccine has been authorized for emergency use in minors between the ages of
16 and 18, as well as minors between ages 12 and 15. As a result, minors across the country have been
getting vaccinated, and accompanying questions have arisen regarding minor consent. Differences in state
minor consent laws have resulted in varying state and local responses. A review of select state requirements,
and additional information as available from certain state or local health departments, is consolidated below.
1. Alabama
Minors above age 14 do not need parental consent to receive the COVID-19 vaccine. Alabama law states that
“any minor who is 14 years of age or older, or has graduated from high school, or is married, or having been
married is divorced or is pregnant may give effective consent to any legally authorized medical, dental, health
or mental health services for himself or herself, and the consent of no other person shall be necessary.” Ala.
Code § 22-8-4.
2. Arizona
Generally, minors cannot consent to vaccination in Arizona. Localities are addressing the issue in different
ways. One Maricopa County vaccination site requires persons under 18 years of age to be accompanied by a
legal guardian and show proof of age on entry. In Pima County, a parent/guardian must be present to complete
consent forms. However, there is an exception: minors can bring a notarized letter from the parent stating that
a designated accompanying adult may complete the forms.
After the FDA authorized the Pfizer-BioNTech vaccine for ages 12-15, Arizona’s Department of Health
Services instructed that parents/guardians must accompany children and sign consent forms attesting that the
minor is at least 12 years old.
3. California
California law generally only allows minors to consent for HPV and Hepatitis B vaccinations. California’s
Department of Public Health issued a guidance document on minor consent on May 13, 2021, indicating that
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parents/guardians may give consent in person, or via written consent, phone, or video communication, so long
as the parent or guardian confirms they have been provided with the Pfizer-BioNTech EUA fact sheet.
The San Francisco Department of Public Health issued a detailed order allowing minors 12 and up to consent
to receive COVID-19 vaccines, whether fully approved or authorized by EUA. The healthcare provider must
reasonably attempt to notify a person with legal authority to consent, who may decline. If the legally
responsible adult objects, then the healthcare provider may not rely on the minor’s consent, but other avenues
may be available (including seeking the order of a court to allow the vaccination over the adult’s objection).
In contrast, L.A. County recommend that a parent/legal guardian accompany the minor if aged 16-17; if not
possible, the minor will be allowed to obtain the vaccine with a completed consent form, signed by the
parent/guardian, so long as they possess a photo ID and proof of age. Minors aged 12-15 must be
accompanied by a parent, legal guardian, or responsible adult (in which case the responsible adult’s name
must appear on the consent form, and the form must be signed by the parent/guardian). In San Diego County,
a parent/legal guardian can consent for minors online upon booking an appointment. At a walk-in site, the
parent/legal guardian must accompany the minor.
4. District of Columbia
DC law states that minors can consent to vaccines recommended by the U.S. Advisory Committee on
Immunization Practices (ACIP) if the minor is at least 11 years of age, capable of giving informed consent, and
the vaccine is provided according to the ACIP schedule. D.C. Mun. Regs. tit. 22, § 22-B600.9. The Pfizer-
BioNTech vaccine was recommended for use in minors between 16-18 years of age by ACIP in December
2020, and in minors between 12-15 years of age in May 2021, but the vaccine has not officially been inserted
into the ACIP schedule. Additionally, Children’s National, a pediatric hospital which was previously handling all
16- and 17-year old’s vaccination efforts in D.C., requires parental consent and a parent/guardian on-site. The
Children’s National website states that this requirement is in place because of the EUA status of the vaccine.
5. Maryland
On May 12, 2021, Governor Larry Hogan announced in a press conference that “minors will need to be
accompanied by a parent or guardian in order to be vaccinated.” Further, the Maryland’s Assistant Secretary of
Health, Bryan Mroz, confirmed the same in a separate statement, adding a consent form requirement.
Baltimore County guidelines explain that minors must be accompanied by an adult. Montgomery County
guidelines explain that minors must either be accompanied by a parent/guardian or have the parent/guardian
consent by phone or online, in which case the minor must provide an ID and proof of age at the appointment.
6. Michigan
The Network has prepared an FAQ which analyzes this specific question relating to Michigan. Please see
COVID-19 FAQs for Michigan Local Health Departments, Part VI. Vaccination. Generally, minors in Michigan
cannot consent for medical care unless emancipated or in a medical emergency. Additionally, an updated FAQ
document issued by Michigan’s Department of Health and Human Services indicates that minors aged 12-17
must obtain parental consent prior to vaccination. Further, C.S. Mott Children’s Hospital’s updated FAQ
information states that parental/guardian consent must either be provided in person by accompanying the
minor or may be provided via written attestation in advance.
7. Minnesota
Minnesota requires parental consent for the COVID-19 vaccine with a few exceptions: (1) minors living apart
from their parent/guardian; (2) married minors, and (3) minors who have given birth. If one of these exceptions
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does not apply, the parent must provide consent and accompany the minor to the vaccination according to a
Minnesota State Health Department resource (Pfizer COVID-19 Vaccine for People Ages 16 and 17).
However, this same resource states:
If a parent/guardian is not able to go with the child to get their vaccine, ask the provider about
their consent process and access to the Emergency Use Authorization fact sheet: Pfizer-
BioNTech COVID-19 Vaccine EUA Fact Sheet for Recipients and Caregivers. This is like the
Vaccine Information Statements given before other routine vaccinations. Make sure all your
questions are answered.
This language indicates that each provider may be conducting consent processes in distinct ways, and that the
state may be permitting alternatives to the in-person parent/guardian requirement. Confirming processes with
specific providers is recommended.
An updated FAQ document indicates that only children aged 12-15 must be accompanied by a parent/guardian
to the vaccination appointment; minors aged 16-17 may be accompanied by a parent/guardian, or may
alternatively provide parent/guardian consent in advance via the online registration process.
8. New York
In New York, parental consent is required for the COVID-19 vaccine. The parent must provide this consent for
16-17-year-olds verbally at the time of vaccination either in person or by phone; providers may also elect to
accept a written statement of consent if phone consent cannot be provided. With respect to minors between
12-15 years of age, a parent or guardian, or person designated by the parent/guardian, should accompany the
minor to the vaccination appointment, and the parent/guardian’s consent is required.
9. Oregon
The Oregon Health Authority (OHA) published a series of FAQs, one of which addresses 16-17-year-olds. The
FAQ states that under Oregon law, minors 15 and up may consent to medical treatment from certain providers
(including physicians, physicians assistants, nurse practitioners, etc.) without parental/guardian consent.
Therefore, the OHA states that consent of a parent/guardian should not be required when the providers
specified in law administer vaccines to minors under 15, but advises providers administering the vaccine to
make it clear at the time an appointment is made whether parental/guardian consent will be requested.
An updated OHA FAQ document dated May 25, 2021, indicates that parental or guardian consent is required
to vaccinate minors between 12-14 years of age. Consent may be provided by accompanying the minor or by
providing written consent in advance; therefore, contacting the specific vaccine provider ahead of time to
confirm consent requirements is recommended.
Additional resources discussing state minor consent laws are available from Vaxteen.org, the Center for
Adolescent Health & the Law, and the National District Attorney’s Association. As indicated by information from
Arizona, California, Maryland, and Oregon, approaches to minor consent may vary based on locality and
individual vaccination site. Confirming requirements with each individual vaccination site in advance is
recommended.
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SUPPORTERS
Support for the Network provided by the Robert Wood Johnson Foundation. The views expressed in this document do not
necessarily reflect the views of the Foundation.
This document was developed by Jen Piatt, J.D., Senior Attorney, Western Region Office, Sandra Day O’Connor College of
Law, Arizona State University, and Mat Swinburne, Associate Director, Network for Public Health Law – Eastern Region Office,
with assistance from Joshua Kalanick, JD candidate. The legal information provided in this document does not constitute
legal advice or legal representation. For legal advice, please consult specific legal counsel in your state.
June 2021
