Federal health officials are seeking public comment on whether to add new categories to the childhood vaccine schedule, according to a request for information HHS published Aug. 24 in the Federal Register.
The public has until Sept. 20 to comment.
The schedule presently sorts vaccination recommendations into three categories: routine, or universal; risk-based; and shared clinical decision-making. The RFI asks whether HHS should add categories such as “recommended, but not during infancy,” “recommended with qualification” and “shared clinical decision-making with qualification.” It does not specify which vaccines would fall into them or define what “qualification” would mean.
The request follows President Donald Trump’s Aug. 10 executive order calling for children to receive fewer vaccines and for the combined measles, mumps and rubella shot to be split into three single-disease doses. It also follows a January overhaul that cut routine childhood immunizations from 18 diseases to 11, which a federal judge blocked in March after a challenge by 15 states and the American Academy of Pediatrics.
For physician leaders, the stakes sit in the coverage details. By the RFI’s own account, a shared clinical decision-making recommendation, once adopted by the CDC director, “triggers the same coverage requirements as a routine recommendation,” including no-cost coverage under the ACA and availability through the Vaccines for Children program. New categories carry no such guarantee; the RFI asks commenters to describe each proposed category’s “intended downstream consequences,” leaving open how coverage would follow.
The document also points to confusion already surrounding shared clinical decision-making. It cites a 2018 survey in which only 24% of pediatric providers could accurately define the category, and a 2021 survey in which 90% to 95% of physicians said adult immunization recommendations with shared clinical decision-making take more time to carry out than routine ones. Fewer than half of physicians in the latter survey knew the vaccines were covered by insurance.
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