The Underground Market for Vaccine Medical Exemptions

Potential customers discover the service through various channels: comments in the Facebook group "Medical Exemption Accepted," posts on the r/unvaccinated subreddit, interviews shared on Rumble, or Google advertisements declaring "We do medical exemptions." Cassandra Clerkin, a mother in upstate New York, reached out to Frontline Health Advocates at the beginning of the 2024–2025 school year after learning the organization had physicians willing to issue exemptions from school vaccination mandates. One of her children had experienced seizures following vaccination, and the family wished to avoid additional shots. Yet New York enforces some of the nation's most stringent immunization policies for school enrollment.

While vaccine requirements have existed in the United States for decades, they have drawn renewed scrutiny and political controversy since the Covid-19 pandemic began. Frontline Health Advocates emerged during the pandemic's vaccination debates with what researchers describe as an unprecedented business model: a standalone entity that furnishes medical exemptions across the country for a flat fee of $495. The organization lists business addresses at a storage facility in Denison, Texas, and a package store in Sedona, Arizona, according to documents reviewed by Undark. Despite minimal public disclosure of its leadership or financial information, the group has quietly built a substantial client base.

Frontline exemptions do sometimes succeed, and certain parents report satisfactory interactions with the organization. However, significant concerns exist regarding whether its legal approach would withstand judicial review—and whether clients fully understand what they are purchasing.

Clerkin described speaking with a Frontline representative by telephone about the procedure. The conversation made obtaining an exemption sound, she recalled, like it "would be pretty seamless." Within days, she received a call from a physician named Andrew Zywiec. Following a $495 credit card charge to a chiropractic business in California, an exemption document arrived via email. The document declared that "The duration of the restriction from receiving VACCINATIONS is PERMANENT," cited multiple health concerns, and cautioned that ignoring the request could result in civil or criminal penalties. Clerkin submitted the exemption to her school district.

The Exemption Landscape

Every state maintains legal provisions requiring certain vaccinations before school enrollment, though some jurisdictions have exemption policies so permissive that immunizations become essentially voluntary. The military enforces vaccine requirements, as do numerous civilian employers including hospitals and nursing homes. Vaccination is frequently mandated in immigration procedures as well.

Some individuals hold sincere objections to vaccination on personal grounds, while others have medical conditions that could make vaccination risky. Options exist for both situations. Most states permit parents to request religious or personal belief exemptions from school vaccine mandates by asserting that vaccination conflicts with their deeply held beliefs. However, such exemptions are sometimes rejected, and four states—California, Connecticut, Maine, and New York—do not permit them at all. A fifth state, West Virginia, currently has uncertain policy on this matter.

In these restrictive states, medical waivers represent the sole pathway to school attendance without required shots. Legitimate reasons for pursuing them exist: some individuals are immunocompromised in ways that make particular vaccines high-risk, or they have experienced adverse reactions to previous vaccinations. In other instances, families may genuinely believe their child cannot safely receive a vaccine but struggle to locate a physician who shares that assessment or will document it on an exemption form.

Medical exemption requests typically increase when regulations become stricter. Following a 2015 measles outbreak at Disneyland that infected hundreds, California eliminated its personal belief exemption. Medical exemption rates more than doubled almost immediately, according to a 2019 analysis by public health researchers. One unnamed health officer told the researchers that the law "created a black market for medical exemptions," with parents turning to the internet to "get medical exemptions from physicians who were not their child's treating physician."

California responded by prosecuting certain healthcare providers for issuing improper medical exemptions and implementing stricter waiver standards. New York, which abolished religious exemptions in 2019, has pursued comparable enforcement; its Department of Health maintains a publicly accessible list of healthcare providers banned or suspended from using immunization registries, displayed on a page titled "School Vaccination Fraud Awareness."

In New York, advocates contend that state regulations have made obtaining medical exemptions unreasonably difficult for many families, regardless of their circumstances. "My understanding is that up until this year, again, a lot of doctors weren't willing to write these medical exemptions," said Chad Davenport, an attorney near Buffalo who regularly represents families pursuing medical exemptions. Davenport recently had a client win an important federal court decision against a Long Island school district that had rejected medical exemptions from at least six healthcare providers.

Frontline Health Advocates filled this gap. According to Davenport, the organization "kind of stepped in and provided families at least an option, or a potential path."

A Unique National Model

Two researchers specializing in vaccination exemptions stated that Frontline appears to operate a model without precedent: Although individual physicians have occasionally become known for dispensing medical exemptions, neither expert had encountered a comprehensive national organization providing this service.

"They're very blatant," observed Dorit Reiss, a professor at UC Law San Francisco who specializes in vaccine law and policy.

William Lionberger, a chiropractor licensed in California since 1981, founded and directs the organization. He previously operated a practice north of San Diego and has also worked as a police officer in a town near Sedona, according to public records. Lionberger declined to participate in an on-the-record interview, and the organization did not respond to questions from Undark. Individuals who have interviewed Lionberger on their programs identify him as connected to America's Frontline Doctors, an organization that opposed Covid-19 vaccines and other public health initiatives while promoting unproven treatments such as hydroxychloroquine.

Frontline Health Advocates registered its website in March 2022, using a name similar to America's Frontline Doctors. By April 2022, the site was inviting visitors to "Get your exemption now." In a 2023 interview, Lionberger described having a "team of medical experts" who "work with all kinds of situations," assessing clients for "regular vax injuries and regular vax exemptive conditions."

He continued: "People now don't even want their kids to get anywhere near a regular vaccine."

Legal Strategies

The organization employs two distinctive legal approaches. The first involves establishing itself as a Private Ministerial Association. Various online resources describing such associations claim they provide special First Amendment protections. A membership application on Frontline's website characterizes the group as "a private, unincorporated ministry that operates as much as possible, outside the jurisdiction of government entities, agencies, officers, agents, contractors, and other representatives, as protected by law."

The second strategy invokes federal disability protections. In his 2023 interview, Lionberger stated they drew on "the most powerful thing that you can bring against discrimination"—specifically, federal protections. A promotional video on the Frontline website makes an equivalent assertion, advertising waivers "supported by the protections under US federal laws." Undark obtained three nearly identical exemptions issued to New York families in 2024. These documents contend that the client's medical exemption requirement is safeguarded under the Americans with Disabilities Act, or ADA, which mandates certain accommodations for individuals with disabilities and other medical needs.

Frontline's 2024 documents suggest that this federal protection supersedes state vaccination statutes—providing a potential workaround for exemption policies nationwide.

Questions About Credentials

Clerkin's exemption combined medical language with legal provisions. The document bore signatures from physician Andrew Zywiec and Christine Pazzula, identified as an administrative law specialist and JD, along with a seal of the United States Department of Justice.

Appearances proved misleading. Frontline maintains no official connection with the Department of Justice. According to her LinkedIn profile, Pazzula earned her law degree from an unaccredited correspondence institution in California, and her name does not appear in bar admission databases for New York, Texas, or Nevada, where her profile indicates she is located. In a brief message to Undark, Pazzula stated she no longer works for Frontline.

A different parent who obtained a Frontline exemption in 2024 later testified under oath that she believed Zywiec held a medical license in New York, but state records show no one by that name has ever been licensed as a physician in the state.

Multiple online testimonials reference Zywiec. Public records reveal a complicated history. According to his CV, Zywiec served in the Army and completed medical school in 2019. He started a pediatrics residency at The Brooklyn Hospital Center in 2020, but the arrangement deteriorated: He subsequently sued the hospital, claiming an unsafe work environment, and filed an employment complaint that included allegations he had been "coerced into taking the so-called Covid-19 vaccine." In court documents from the lawsuit, a hospital official characterized an employee who was "spotty and difficult." In 2021, Zywiec's fellow residents submitted a letter to supervisors alleging he had made offensive comments to colleagues and treated nurses poorly, noting additionally that he "would delay care to patients because he wanted to participate in procedures unrelated to his patients because they interested him."

Zywiec operates an online medical practice where he identifies himself as "an international medical doctor and board-certified indigenous medicine provider" and provides various services, including a $150, 30-minute "Medical Excuse/Note" consultation producing a "legitimate medical excuse tailored to your situation." On X, he has accumulated tens of thousands of followers and regularly posts material questioning vaccine safety.

Frontline's promotional video describes the exemptions as "signed by state-licensed physicians with full credentials." Zywiec's name does not appear in the national physician database maintained by the Federation of State Medical Boards. In a brief email, Zywiec directed interview requests to Frontline. He did not provide responses to questions from Undark, and Frontline did not address inquiries about Zywiec's license status.

The school district rejected Clerkin's exemption. In its response, the district noted that New York law mandates that exemptions be signed by a state-licensed physician. Clerkin acknowledged knowing Zywiec lacked a New York license but believed Frontline's confidence in their strategy might overcome this obstacle. It did not. "I feel like they talk this big thing," Clerkin said. However, she added, "if you know that you can't help these children, and you're just preying on these mothers who will do anything for their children, that is evil."

Mixed Results and Legal Uncertainty

Some Frontline exemptions have been accepted in New York. "I can certainly tell you that there have been some people, even this year, who have been able to get their Frontline Health waivers accepted," Davenport told Undark. However, he noted that courts have not yet evaluated the claim that an exemption invoking federal law will supersede the state's requirement that exemptions come from a New York-licensed physician. He does not recommend Frontline to his clients. "I basically tell them, although Frontline may technically be correct, it's not a good legal position for you to be in," Davenport said. "And so I always advise them to try to get a New York state waiver signed by a New York state doctor and then submit that, because that puts you in the best legal position."

Frontline's website includes a video warning prospective clients that exemptions may be rejected, noting that the group "cannot guarantee that an unknown person you are engaging with is going to abide by federal laws." Yet Rita Palma, a health freedom activist on Long Island who has assisted numerous families seeking medical exemptions, told Undark that she believes parents remain confused about the waivers' actual scope. "What I'm getting from parents is that Frontline Health Advocates say that federal law overrides state law," she said. The question of whether that principle applies to vaccine exemptions remains unresolved.

The $495 charge—with additional fees for expedited processing—represents a substantial expense for many households. "They've made a nice killing in New York," Palma said. "I hate to put it like that, but they've definitely gotten a lot of parents to pay them to get exemptions."

Determining how many waivers Frontline has distributed is challenging. Online forums contain accounts of successful school submissions. "I got lifetime medical exemptions for my children," one parent wrote in a Facebook group in April, noting she had no affiliation with Frontline. The group is "replete with lawyers to respond to any pushback from schools," she noted.

A Connecticut mother told Undark she contacted Frontline in 2024 when her son required a flu shot to remain in daycare. "I was looking around for a way to get an exemption," she said, speaking anonymously due to professional privacy concerns. Following a phone consultation with a licensed pediatrician in Texas, she received an exemption. The daycare accepted it. "It was a pretty smooth experience, overall," she said.

"I was aware that it was a gamble," the mother said; Frontline had cautioned that the exemption might not be accepted. "But then they kind of were like, well, you know, technically, if they don't accept it, it's illegal because it's protected by ADA and all that kind of thing," she said.

Regulatory Scrutiny

Public health authorities have begun monitoring the organization. Los Angeles County's public health department website displays a prominent red warning that Frontline exemptions do not work in California. In October 2024, Connecticut's School Nurse Advisory Council meeting minutes characterized Frontline as issuing what the council considered "fraudulent" exemptions to families. Connecticut Public Health spokesperson Brittany Schaefer told Undark in late September that Frontline is under "an active investigation."

Undark asked three legal specialists to examine an exemption issued to a New York family in September 2024, obtained through court records. "It seems to be a fill-in-the-blank type of form," said Barbara Hoffman, a disability law expert at Rutgers Law School. The waiver, in Hoffman's assessment, overstates the typical penalties for ADA violations. School districts, employers, or others receiving this document, she suggested, might conclude that "it's not worth the effort to reject this."

"This looks like an official document," she continued, pointing to the Department of Justice seal and references to potential civil penalties. "It's designed to intimidate somebody who doesn't really know better, or just doesn't want to risk any potential litigation."

Can invoking the ADA truly override state-level vaccine mandates? Reiss expressed doubt, noting that state law has typically prevailed in comparable disputes. "My expectation," she wrote in an email, "is that that won't hold."

Source: Ars Technica