Public Comment on December 4-5, 2025 ACIP Meeting

Comments for the December 2025 Meeting of the Advisory Committee on Immunization Practices (Docket No. CDC-2025-0783) 

To the Advisory Committee on Immunization Practices:

We are writing on behalf of HealthHIV and the National Coalition for LGBTQ Health (the Coalition), in response to Docket No. CDC-2025-0783, about how the December ACIP proceedings—particularly the Hepatitis B birth-dose discussions and related agenda items—will affect national immunization standards and protections connected to them.

It comes after the recent reconstitution of ACIP members; and statements added to CDC’s public-facing vaccine pages have reopened long-settled questions about childhood vaccines and autism. This shift marks a significant departure from long-established, evidence-based messaging that had historically anchored CDC’s immunization guidance.

And as of the October 9 update to the ACIP Work Groups page, CDC lists active Work Groups by topic but doesn’t identify participating members, external experts, or liaison organizations, making it unclear what scientific expertise that historically informed Work Group deliberations was applied in preparing the materials for the December 4–5 agenda.

All of this is important context for public health, as ACIP recommendations are referenced in nearly 600 state statutes and regulations that govern everything from school immunization laws and insurance mandates to provider protocols. Any single departure from evidence-based science ruptures the foundation of public health and ripples across the entire U.S. health system—directly affecting children, older adults, and immunocompromised people, including those we represent and the hundreds of partner organizations we work alongside. 

These amendments in our shared, national understanding (and expectations) of science (and scientists) are happening against a backdrop of declining vaccination rates and resurgent outbreaks of vaccine-preventable diseases, including measles, pertussis, mpox, and COVID-19. And the consequences for our communities couldn’t be more severe, placing avoidable sickness, deaths, comorbidities, greater lifelong disability, and shrinking quality of life in sharper relief. For older adults living with HIV and immunocompromised folks, reduced vaccine access writ large means more social isolation and heightened daily risks; something as a person with HIV I grapple with daily, and especially since COVID-19  emerged. 

Mandates context and public sentiment

These broader drifts from science are already showing real-world consequences. Case in point. On September 3, 2025, Florida announced plans to roll back long-standing school vaccine requirements—an unmatched step with national implications. With details still evolving, the announcement underscores how quickly state protections shift when national guidance changes, particularly when universal requirements are reframed as matters of individual clinical judgment. In attempting to recast “shared clinical decision-making” as a substitute for universal recommendations—presenting it instead as a “freedom-forward, individualized alternative”—ACIP is, in reality, weakening universal health recommendations, period. It further shifts responsibility away from population-level protection (including herd immunity) and onto individual clinicians and patients with less access to scientific guidance, and fractures what was previously uniform national guidance.

And as of November 24, 2025, while all 50 states and Washington, D.C., still (technically) require vaccinations for school attendance, Florida’s pending rollback makes clear that these protections are no longer reliably stable and can change rapidly when national standards are blurred, or when politics motivate them. Most states allow non-medical exemptions (the policy space this committee is trying to pry open), but only a small number don’t: California, Connecticut, Maine, and New York. West Virginia’s status remains in legal flux. A January 2025 executive order there attempted to allow religious exemptions, but the State Board of Education continues to enforce medical-only rules; a narrow court injunction applies only to a few families in one county, without any statewide change.

To be clear (even as HHS leans on “freedom” arguments to roll them back), public health mandates exist because they work—they lead to higher vaccination coverage, fewer outbreaks, and fewer deaths. This practice reaches back to the nation’s founding; George Washington ordered smallpox inoculation for Continental soldiers to protect the force and the expanding country. Today, public backing remains broad; 79% of U.S. adults support routine childhood vaccine requirements for school, across party lines. 

Hepatitis B and the December ACIP agenda

The December agenda places the Hepatitis B birth dose squarely before the ACIP committee. Unraveling this recommendation to accommodate “choice” isn’t a neutral policy shift. It directly weakens the only intervention that reliably prevents early infection and future liver disease. To that, universal infant vaccination has reduced acute Hepatitis B among children and adolescents by more than 99%, and before this recommendation was adopted, an estimated 18,000 children were infected each year before age ten—nearly half through perinatal transmission. Because ninety percent of exposed infants develop lifelong chronic infection, the birth dose remains the single most reliable intervention for preventing early infection and future liver disease. 

A negative maternal test during pregnancy does not eliminate risk: results can be false negatives, infections can occur after testing, and clinical monitoring is inconsistent across settings. Hepatitis B is highly infectious, frequently asymptomatic, and can be transmitted by household members with unrecognized infection. For these reasons, a universal birth dose is the only approach that closes gaps created by missed, inaccurate, or delayed screening.

Removing the universal recommendation would create confusion, delay protection during the period of highest vulnerability, and introduce avoidable coverage complications. ACIP’s votes directly influence what insurers cover as required benefits; weakening a universal standard by designating the birth dose as optional or individualized would undercut access and create highly uneven uptake across health systems. 

Transparent, expert-driven deliberation has long shaped the strength and credibility of ACIP recommendations, and the absence of long-standing external immunization experts in Work Group discussions has narrowed the scientific review that typically informs these decisions. As implementation science becomes even more critical for preventing new and controllable epidemics the reliability of ACIP’s process—and the clarity of its downstream effects—take on even greater significance. Hepatitis B elimination goals intersect directly with HIV prevention and care, and any retrenchment of longstanding recommendations will ripple across state law, insurance coverage, and school-entry protections.

We urge ACIP to:

• Maintain the universal Hepatitis B vaccination recommendations for infants
• Reaffirm transparent vaccine processes and resultant procedures. Safeguard ACIP’s independence, transparency, and evidence-based approach with experts from the field.
• Acknowledge downstream effects. Because state laws and coverage rules key off ACIP recommendations, any retrenchment of longstanding recommendations will limit insurer obligations and confuse providers; and ultimately shrink our school protections. Recognize the end-user effects of ACIP recommendations on state law, school immunization requirements, and insurance coverage nationwide. 

In short, we ask the ACIP committee to vote for policies that protect universal vaccine access and uphold scientific independence. Thank you for your consideration of this comment submitted in response to Docket No. CDC-2025-0783.

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