Not everything was quite as it seemed

Frontline Health Advocates provides medical exemption notes—for a fee. What exactly are they selling?

Maybe a client hears about them in the comment section of the Facebook group “Medical Exemption Accepted,” or on the r/unvaccinated forum on Reddit. Maybe it’s through an interview posted on the video-sharing platform Rumble. Or maybe it’s the targeted advertisements on Google: “We do medical exemptions.”

Cassandra Clerkin, a mother in upstate New York, first got in touch with Frontline Health Advocates near the start of the 2024–2025 school year, after hearing they had doctors who would write exemptions from school immunization requirements. One of Clerkin’s children, she said, had suffered seizures after receiving a vaccine. The family didn’t want more shots. But New York has some of the country’s strictest school immunization policies.

Perhaps Frontline could help.

Vaccine mandates have a long history in the United States, but they’ve been subject to fresh public attention—and partisan dispute—since the start of the Covid-19 pandemic. Frontline Health Advocates seemingly emerged from pandemic-era battles with a model that, experts say, appears to be unique: It bills itself as a standalone organization that supplies people across the US with medical exemptions from vaccination requirements—for a fee of $495.

On forms obtained by Undark, Frontline’s listed addresses are a storage facility in Denison, Texas, and a package store in Sedona, Arizona. The group publishes little information online about its leadership or finances, but it has quietly developed a following.

There’s little question that Frontline exemptions sometimes work, and some parents report positive experiences with the organization. But there are real questions about whether its legal strategy would hold up in court—and whether clients are confused about what, precisely, they are receiving.

In upstate New York, Clerkin said she spoke with a representative from Frontline by phone about the process. They made it sound, she said, like getting an exemption “would be pretty seamless.”

Soon after, she recalled, she received a call from a doctor named Andrew Zywiec. A week after the family issued a credit card payment of $495 to a chiropractic firm in California, the medical exemption arrived by email. “The duration of the restriction from receiving VACCINATIONS is PERMANENT,” the document stated, citing a range of health concerns, and warning that civil or criminal penalties could result if the school district ignored the request.

Clerkin submitted the document to the district.

Every state in the country has legal language on the books that seems to require certain immunizations before children can enroll in school—although in some places exemption policies are so lax that shots are effectively optional. The military also has vaccine requirements, as do some civilian workplaces, including many hospitals and nursing homes. Immigration proceedings, too, often require applicants to receive shots.

Some people may register personal objections to vaccination, or they may have medical conditions that could make receiving a shot dangerous. Workarounds exist. Most states, for example, allow parents to apply for religious or personal belief exemptions from school vaccine requirements by stating that they object to vaccination due to deeply held convictions. But those exemptions are sometimes denied, and in four states—California, Connecticut, Maine, and New York—they aren’t an option at all. (The policy in a fifth state, West Virginia, is currently in flux.)

In those states, the only way to attend school without a required shot is to receive a medical waiver. There are real reasons for some people to pursue them: They may be immunocompromised in a way that makes certain vaccines high-risk, or they may have had a bad reaction to a shot in the past. In some cases, families may earnestly believe their child cannot safely receive a vaccine, but have difficulty finding a physician who agrees, or who is willing to attest to that on an exemption.

Interest in medical exemptions tends to grow when laws tighten. In 2015, after a measles outbreak at Disneyland sickened hundreds of people, California lawmakers ended the state’s personal belief exemption. Almost immediately, the medical exemption rate more than doubled, according to a 2019 paper by a team of public health researchers. The law “created a black market for medical exemptions,” one unnamed health officer told the researchers. Parents, the officer added, would go online and “get medical exemptions from physicians who were not their child’s treating physician.”

The state cracked down, prosecuting some health care providers for allegedly providing improper medical exemptions, and tightening the rules for receiving a waiver. New York, which eliminated religious exemptions in 2019, has taken similar steps; the Department of Health maintains a public list of health care providers who have been banned or suspended from using immunization registries in the state, on a webpage titled “School Vaccination Fraud Awareness.”

In New York, advocates say, state policies have made it prohibitively difficult for some families to obtain medical exemptions, regardless of the reason. “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 outside Buffalo, New York, who often represents families seeking medical exemptions. (One of his clients recently won a key ruling in a federal court case against a Long Island school district that had denied medical exemptions from at least six health care providers.)

Enter Frontline Health Advocates. The organization, Davenport said, “kind of stepped in and provided families at least an option, or a potential path.”

Two researchers who have studied vaccination exemptions in the United States said the organization appears to have a unique model: While individual doctors have sometimes gained a reputation for supplying medical exemptions, neither expert had seen a full-fledged national organization offering those services.

“They’re very blatant,” said Dorit Reiss, a professor at UC Law San Francisco who studies vaccine law and policy.

The group’s founder and director is William Lionberger, a chiropractor who has been licensed to practice in California since 1981, and who once maintained a practice north of San Diego. According to public records, he has also served as a police officer in a town near Sedona. (Lionberger declined a request for an on-the-record interview, and the organization did not answer a list of questions from Undark.) Interviewers who have hosted Lionberger on their shows describe him as affiliated with America’s Frontline Doctors, a group that opposed Covid-19 vaccines and other public health measures while promoting unproven treatments like hydroxychloroquine.

Frontline Health Advocates’ webpage was first registered in March 2022, with a name echoing that of America’s Frontline Doctors. By April of that year, the website 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,” evaluating clients both for “regular vax injuries and regular vax exemptive conditions.”

He added: “People now don’t even want their kids to get anywhere near a regular vaccine.”

The group employs a pair of distinctive legal strategies. One of these is to form itself as something called a Private Ministerial Association. Online, some groups that help set up such private associations describe them as offering special First Amendment protections. A membership application document hosted on Frontline’s website describes 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.”

Another strategy is to invoke federal disability law. In the 2023 interview, Lionberger boasted that they drew on “the most powerful thing that you can bring against discrimination”—specifically, federal protections. A promotional video posted on the Frontline website makes a similar claim, advertising waivers “supported by the protections under US federal laws.” Undark obtained three near-identical exemptions sent to New York families in 2024. In them, Frontline argues that the client’s need for a medical exemption is protected under the Americans with Disabilities Act, or ADA, which guarantees certain accommodations for people with disabilities and other medical needs.

In Frontline documents from 2024, the organization suggests that this federal protection supersedes state vaccination laws—offering a way around exemption policies across the country.

In New York, Clerkin had received a document combining medical language with legal details. The document bore the signatures of doctor Andrew Zywiec and an administrative law specialist and JD, Christine Pazzula, along with the seal of the United States Department of Justice.

Not everything was quite as it seemed. Frontline has no relationship with the Department of Justice. Pazzula, according to her LinkedIn profile, had received her legal degree from an unaccredited correspondence school in California, and her name does not appear in databases of attorneys admitted to the bar in New York, Texas, or Nevada, where her LinkedIn profile says she is based. (In a brief email to Undark, Pazzula said she no longer works for Frontline.)

Another parent who received a Frontline exemption in 2024 would later testify under oath that she believed Zywiec to be a physician licensed in the state of New York, but state records show that nobody named Zywiec has ever held a medical license in the state.

Multiple online testimonials about Frontline mention Zywiec. A review of public records suggests a turbulent history. Zywiec served in the Army and graduated from medical school in 2019, according to a CV. In 2020, he began a pediatrics residency at The Brooklyn Hospital Center, but the relationship soured: He ultimately sued the hospital, alleging an unsafe work environment, and filed an employment complaint that, among other concerns, said he had been “coerced into taking the so-called Covid-19 vaccine.” In court documents associated with the lawsuit, a hospital official described an employee who was “spotty and difficult.” In 2021, Zywiec’s co-residents had written a letter to their superiors alleging that he had made offensive remarks to colleagues and treated nurses poorly, also writing that he “would delay care to patients because he wanted to participate in procedures unrelated to his patients because they interested him.”

Zywiec maintains an online medical practice, where he describes himself as “an international medical doctor and board-certified indigenous medicine provider” and offers a range of services, including a $150, 30-minute, “Medical Excuse/Note” consultation that yields a “legitimate medical excuse tailored to your situation.” On X, where he has amassed a following in the tens of thousands, Zywiec regularly shares content about the dangers of vaccines.

The promotional video on Frontline’s website describes the exemptions as “signed by state-licensed physicians with full credentials.” Zywiec’s name does not appear in a national database of licensed physicians maintained by the Federation of State Medical Boards. (In a brief email, Zywiec referred interview requests to Frontline. He did not answer a list of questions from Undark, and Frontline did not respond to a question about Zywiec’s license status.)

The exemption that Zywiec had signed for Clerkin was denied. In a letter, the school district explained that New York law requires exemptions to be signed by a physician licensed in the state. Clerkin said that she was aware Zywiec was not licensed in New York, but Frontline seemed confident in their approach, and she thought it might work. That did not pan out, she said. “I feel like they talk this big thing,” Clerkin said. But, 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.”

Some Frontline exemptions do get through, at least 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. But, he said, courts have not tested the argument that an exemption invoking federal law will trump the state’s requirement that the exemption comes from a New York-licensed physician. He does not recommend Frontline to 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.”

In a video on its website, Frontline warns potential clients that exemptions may be denied, noting that the group “cannot guarantee that an unknown person you are engaging with is going to abide by federal laws.” But Rita Palma, a health freedom activist on Long Island who has worked with many families seeking medical exemptions, told Undark that she thinks parents are still confused about the limitations of the waivers. “What I’m getting from parents is that Frontline Health Advocates say that federal law overrides state law,” she said. Whether or not that’s true in the case of vaccine exemptions remains unclear.

The $495 fee—extra for expedited service—is a steep price for some families. “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.”

It’s difficult to know how many waivers Frontline has sold. In online forums, people describe successes with schools. “I got lifetime medical exemptions for my children,” one parent wrote in a Facebook group in April, noting that she was not affiliated with Frontline. The group is “replete with lawyers to respond to any pushback from schools,” she added.

One mother in Connecticut told Undark that she had contacted Frontline in 2024, when her son needed a flu shot to stay in daycare. “I was looking around for a way to get an exemption,” she said. (The mother spoke on condition of anonymity, citing a professional need for privacy.) After a phone call with a licensed pediatrician in Texas, she received an exemption. The daycare, she said, accepted it. “It was a pretty smooth experience, overall,” she said.

“I was aware that it was a gamble,” the mother said; Frontline had told her 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.

The group has attracted attention from some public health officials. In Los Angeles County, a public health department website is topped by a large red banner warning that Frontline exemptions don’t work in California. In October 2024, in Connecticut, minutes from a meeting of the state’s School Nurse Advisory Council described Frontline as providing what the council believed to be “fraudulent” exemptions to families. A spokesperson for Connecticut Public Health, Brittany Schaefer, told Undark in late September that Frontline is the subject of “an active investigation.”

Undark asked three legal experts to review a copy of an exemption issued to a family in New York in September 2024 and obtained via court records. “It seems to be a fill-in-the-blank type of form,” said Barbara Hoffman, an expert in disability law at Rutgers Law School. The waiver, Hoffman believes, overstates the penalties generally levied for ADA infractions. School districts, employers, or others who received this form, she speculated, might feel like “it’s not worth the effort to reject this.”

“This looks like an official document,” she added, highlighting the seal of the Department of Justice 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.”

Could invoking the ADA really override state-level vaccine requirements? Reiss, the UC Law San Francisco expert, was skeptical, noting that state law has generally held in similar cases. “My expectation,” she wrote in an email, “is that that won’t hold.”

This article was originally published on Undark. Read the original article.