Assessing the Impact of Changes to Federal Vaccine Recommendations on State Immunization Policies

Published
By
Victoria Willens
Health Policy
Vaccines
Picture of smiling baby

In light of recent changes to federal immunization recommendations and ongoing disruption to the advisory process, it's important to understand how these changes could impact vaccine access at the state level.

In partnership with American Families for Vaccines (AFV), researchers at the International Vaccine Access Center examined direct and indirect references to federal immunization guidelines within the laws of 14 focus states with active AFV chapters. These findings are reflected in the Vaccine Policy Atlas, a new policy resource that can help lawmakers, advocates, and public health officials understand how their state’s laws are linked with federal immunization guidance.

ACIP recommendations impact both federal and state immunization policies.

The Advisory Committee on Immunization Practices (ACIP), a group tasked with making recommendations on vaccines in the United States, has postponed its February meeting, the first meeting scheduled since the CDC announced an overhaul to the childhood immunization schedule earlier this year. 

Recommendations from ACIP are typically incorporated into the CDC immunization schedule, informing which vaccines are recommended for each age group and their dosing schedule, and have downstream consequences for both federal and state immunization policies. ACIP recommendations are embedded in immunization laws at the state level, governing everything from school immunization requirements to insurance coverage for vaccines. 

States vary in their reliance on ACIP recommendations.

While some states rely solely on ACIP guidance in many of their immunization laws, others have moved to distance themselves from federal guidelines, amending their laws to allow for consideration of recommendations from other expert groups. For example, prior to 2025, Colorado developed its school immunization requirements based only on ACIP guidance. The law has since been changed to incorporate recommendations from ACIP, the American Academy of Family Physicians (AAFP), the American College of Obstetricians and Gynecologists (ACOG), and the American College of Physicians (ACP) in state vaccination practices. Other states have less flexibility in their immunization laws, relying solely on ACIP guidance. 

It is not clear how decoupling these laws from federal requirements will work in practice.

ACIP recommendations have widespread impacts on immunization laws. The 14 states reviewed had 103 laws that linked their immunization guidelines to federal policy. ACIP references generally fell into six areas: 

  • Vaccination requirements for enrollment or attendance in schools, colleges and universities, or daycares. Of the 14 states examined, half (7) use ACIP recommendations, when setting these requirements, while four additional states consider ACIP guidance alongside guidance from other organizations. In most cases, it is unclear which guidance states should prioritize in the case of misalignment or disagreement. As some states work to distance themselves from ACIP recommendations, this may add confusion to the implementation of these policies.
  • Payer coverage for vaccines. More than half (8) of the states analyzed have at least one law dictating payer coverage for vaccines based solely on ACIP recommendations. Although many health plans have committed to paying for those vaccines recommended by ACIP as of September 2025, at least through the end of 2026, future changes to ACIP recommendations could impose a financial burden for individuals in some states.
  • Scope of practice for pharmacists, paramedics, naturopathic doctors, and other non-physician health professionals. More than half (8) of the 14 states examined have laws governing the scope of practice for pharmacists, paramedics, naturopathic doctors, and other non-physician health professionals that are tightly linked to ACIP recommendations. In these states, vaccines that are no longer recommended by ACIP would be less accessible, potentially requiring individuals to make a doctor’s appointment in order to receive a vaccine.
  • Vaccination requirements for health care workers and patients. Of the states in our analysis, more than half (8) reference ACIP in at least one law regarding vaccination requirements for health workers and for patients in hospitals and long-term care facilities. Changes to these requirements could leave vulnerable populations, such as immunocompromised hospital patients and the elderly, less protected against disease.
  • Provision of vaccination information to the public. Five of the states examined include ACIP recommendations in laws related to the provision of vaccination information to the public. These laws can help to maintain the uptake of certain vaccines by vulnerable populations, such as college students living on campus or newborn infants, and so changes to ACIP recommendations could limit their impact.
  • State vaccine purchasing. One state in our analysis relies on ACIP recommendations to guide vaccine purchasing by the state. Changes to these recommendations could reduce access to vaccines, especially for the uninsured or low-income families.

Researchers also found ACIP references in laws related to vaccination requirements for foster families and post-exposure rabies treatment, among others.

The immunization landscape in the U.S. is constantly evolving.

Already in the 2026 legislative session, hundreds of bills could affect immunization at the state level. Several states are proposing to distance themselves from federal vaccination recommendations by incorporating guidance from other trusted organizations, while others are moving to weaken vaccine requirements. Although the Vaccine Policy Atlas is not a real-time resource, it will be updated as needed to reflect significant changes in state immunization policy, with the potential to expand to include additional states moving forward.