September 20, 2021

On September 16, 2021, the Virginia Department of Health announced that individuals can obtain QR codes – a type of barcode that can be scanned using smartphones – to obtain their Virginia COVID-19 vaccination records. With more vaccination requirements on the horizon,[1] the ability to use a QR code to verify individuals’ vaccination status may prove to be an effective tool for both individuals and employers.

QR codes, which stand for “quick response,” are already utilized in a variety of sectors, from retail to financial services. These images allow individuals to securely share information. Virginia is the fifth state in the U.S. to begin utilizing the SMART Health format for QR codes. The Smart Health Card was developed by the Vaccination Credential Initiative (“VCI”), a coalition of private and public organizations, such as Microsoft, Oracle, and the Mayo Clinic, using technology from Boston Children’s Hospital.

Businesses and employers can scan these QR codes to verify an individual’s vaccination status by downloading the SMART Health Verifier App. When a code is scanned the app will display one of three colored notifications: green (verified), orange (partially verified – the SMART Health Card is valid, but the issuer is not recognized2), or red (not verified – the SMART Health Card cannot be verified). The Smart Health Card will also show the holder’s name and date of birth, as well as clinical information related to the vaccine, such as dates, manufacturer, and location. Each QR code is digitally signed by the Virginia Department of Health, making them much more difficult to forge than a paper vaccination record.

Individuals can obtain a free QR code by visiting, clicking “Need a copy of your vaccination record?,” and entering their information. QR codes can then be saved on phones or computers as digital files or printed on a piece of paper. Most people vaccinated in Virginia will be able to automatically obtain a QR code. Codes are available to anyone whose vaccination record includes a valid phone number and is in the Virginia Immunization Information System (“VIIS”). Almost all doses of COVID-19 vaccinations administered in Virginia, whether at a pharmacy, doctors office, health department clinic, or community vaccination center, are reported to the VIIS. Some doses administered outside of the state to Virginia residents may also be reported. However, doses administered by federal agencies, such as the Department of Veterans Affairs, are not reported to VIIS. If an individual cannot obtain their record automatically, they may call 877-VAX-IN-VA (877-829-4682, TTY users call 7-1-1) for assistance. Expect delays until the call volume diminishes.

The adoption of QR codes offers Virginia businesses and employers an efficient and secure manner to verify individuals’ vaccination status. Employers should consider incorporating the use of QR codes in their preparations to conform with the upcoming federal vaccine mandates, existing OSHA requirements, or employer policies related to COVID-19 vaccinations.

If you have questions or need assistance regarding compliance with these vaccine requirements and other employment laws, please contact a member of Hancock Daniel’s Labor & Employment team. For any other concerns arising from the pandemic, please contact a member of our COVID-19 Task Force.

Click here for a full PDF version of this advisory.


[1] Hancock Daniel’s recent client advisory outlining new vaccine mandates for health care workers and large employers can be found here.

2 An issuer may not be recognized if they are not listed in the CommonTrust Network’s Registry of trusted issuers. If the issuer is not recognized, the issuer URL will be provided.

The information contained in this advisory is for general educational purposes only. It is presented with the understanding that neither the author nor Hancock, Daniel & Johnson, P.C., is offering any legal or other professional services. Since the law in many areas is complex and can change rapidly, this information may not apply to a given factual situation and can become outdated. Individuals desiring legal advice should consult legal counsel for up-to-date and fact-specific advice. Under no circumstances will the author or Hancock, Daniel & Johnson, P.C. be liable for any direct, indirect, or consequential damages resulting from the use of this material.

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