Public Comment on September 18-19, 2025 ACIP Meeting

Re: Public Comment on Docket No. CDC-2025-0454—September 18–19 ACIP Meeting

Dear ACIP Members:

We are writing on behalf of HealthHIV and the National Coalition for LGBTQ Health, in response to Docket No. CDC-2025-0454, to express our serious concerns about the impact HHS immunization policies will have on all Americans. This comes after the abrupt termination of all 17 members of the ACIP committee by Secretary of Health Robert F. Kennedy, Jr., and the installation of new appointees. The removal of independent experts from ACIP is unprecedented, and that decision could hold negative generational consequences for public health and may further undermine this committee’s scientific integrity and public trust.

All of the former ACIP members were respected scientists and trusted doctors, and their advice shaped CDC policy and influenced public health initiatives and programs across the country. Their expertise and ensuing recommendations shaped public insurance coverage requirements, Medicaid benefits, and the Vaccines for Children program.

In fact, ACIP recommendations are referenced in nearly 600 state statutes and regulations that govern everything from school immunization laws and insurance mandates to provider protocols. And any single departure from evidence-based science ruptures the foundation of public health. This rupture then 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 alterations to the fabric of science are occurring 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: furthering avoidable deaths and comorbidities, greater lifelong disability, and shrinking quality of life. For older adults living with HIV, whom we work with directly, this sentiment of reduced vaccine access writ large means social isolation and heightened daily risk; something I grapple with daily since COVID emerged. For communities that already face disproportionate burdens, we’re going to be left even more vulnerable. And this is not a healthy America, either in the body politic or in the lived realities of its citizens.

Mandates context and public sentiment

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 in that one state’s landscape, the announcement underscores how quickly state protections can erode if national guidance weakens.

Even so, as of September 2025, all 50 states and Washington, D.C., still require vaccinations for school attendance, consistent with longstanding immunization policy. Most states allow non-medical exemptions, but only a small number do not: California, Connecticut, Maine, and New York. West Virginia’s exemption status is in legal flux: the governor issued an executive order in January 2025 to allow religious exemptions, but the state Board of Education continues to enforce the longstanding medical-only law. The result is piecemeal and confusing—ongoing lawsuits and a limited court injunction for 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. But this practice reaches back to the nation’s founding; in fact, 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. 

COVID-19 access and clarity

The new policies imposed by RFK Jr., Marty Makary, and Vinay Prasad restrict access to COVID-19 vaccines. Evidence shows that receiving a COVID-19 vaccine within the past year reduces the risk of symptoms, severe disease, disability, Long COVID, and death across age groups. 

Universal access to updated COVID-19 vaccines at no cost is essential. Additional efficacy studies are unnecessary; instead they disrespect years of grounded data, delay protection, and create confusion—ultimately diverting resources that could support population health.

Process breakdown

Transparent, expert-driven process and subsequent decisions are collapsing under the weight of unevenly applied policy. When the FDA canceled the 2025 VRBPAC session on influenza strain selection and then issued strain recommendations without the public advisory meeting, it only fueled concerns that expert panels are being sidelined. The downstream effect on our nation’s future science-builders is stalling, and ACIP’s commitment to open deliberation today becomes even more critical to shape future paths that could include new but controllable epidemics. It is inconceivable to us, as implementation science becomes more vital, that this is not being factored in by HHS.

The published agenda for this meeting lists possible votes on COVID-19, Hepatitis B, MMRV, and RSV, with Vaccines for Children under consideration for each. But what actions will actually be taken is not specified, leaving stakeholders without clarity on scope or even the committee’s underlying intent. 

From our Coalition work and HealthHIV’s focus on HIV, viral hepatitis, and the needs of older adults, these issues are not abstract. Hepatitis B vaccination is central to elimination goals and intersects directly with HIV prevention and care. COVID and RSV remain daily risks for older persons and immunocompromised populations, especially people aging with HIV. And measles/MMRV outbreaks show how fragile vaccine protections become when mandates and access weaken.

We urge ACIP to:

• Reinstate universal, no-cost access COVID-19 vaccination recommendations for all ages, with administration authorized at least twice yearly to account for waning immunity.
• 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, vaccination is (and has been since this country’s great founding) one of the most effective public health tools ever developed and dispensed. ACIP’s role in access and public confidence has been indispensable since 1964. Because of this science-based work, America has been able to prevent large-scale outbreaks of measles, pertussis, and polio, while ensuring nationwide access through programs like Vaccines for Children. More recently, the vaccines developed under Operation Warp Speed—celebrated worldwide by adversaries and allies alike as a landmark U.S.-driven achievement—were only made available to the public through ACIP’s independent review and recommendation process.

We ask this 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-2025-0454.

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