New and updated
1. New schedule
On Monday, Jan. 5, citing a memorandum from the President, HHS abruptly announced a new childhood immunization schedule. This schedule reduces the number of diseases for which immunization is recommended from 17 to 11, and the number of routinely recommended vaccines from 13 to 7. Dropped vaccine recommendations affect influenza, hepatitis B and C, rotavirus, Covid, and meningitis. These vaccines will remain available under "shared clinical decisionmaking," which is short of a full recommendation but calls for additional discussion between patients and their clinicians before proceeding.
The new schedule was developed without meaningful input from experts at CDC or CDC’s Advisory Committee on Immunization Practices, and without any transparent, public process.
As part of the rollout, HHS issued a 33-page “assessment” of the US childhood immunization schedule, written by two officials appointed by the new administration. It provided no assessment of the risk and benefit of particular vaccines, but focused instead on the immunization practices of other countries, describing the US as an “outlier” in terms of the number of vaccines offered. Career expert scientists were excluded from this process.
Insurance coverage, including coverage by the Vaccines for Children Program, is expected to continue–with one possible exception. The new schedule reduces the number of human papillomavirus (HPV) vaccine doses from 2 to 1 (whether this is advisable is disputed), and it is unclear whether payors will be required to cover the second dose for patients who wish to use the vaccine as recommended on the FDA-approved label.
Editors’ note: There is not a scientific rationale for dropping recommendations in the new schedule. Parents should understand that the nation’s pediatricians continue to recommend that children be protected against all of these diseases.
2. Medicaid quality reporting
At the end of December, CMS communicated to states that it would no longer require states to report how many children enrolled in Medicaid or the Children’s Health Insurance Program received immunizations.
This reporting requirement was 15 years in the making, tracing back to legislation passed in 2009. CMS established the requirement after years of consensus-building and voluntary reporting. CMS did not provide a rationale for the current change, nor is it clear that the federal government has the authority simply to drop the requirement. Congress provided that changes should be made after consultation with a long list of affected groups:
‘‘(A) States; ‘‘(B) pediatricians, children’s hospitals, and other primary and specialized pediatric health care professionals (including members of the allied health professions) who specialize in the care and treatment of children, particularly children with special physical, mental, and developmental health care needs; ‘‘(C) dental professionals, including pediatric dental professionals; (D) health care providers that furnish primary health care to children and families who live in urban and rural medically underserved communities or who are members of distinct population sub-groups at heightened risk for poor health outcomes; ‘‘(E) national organizations representing children, including children with disabilities and children with chronic conditions; ‘‘(F) national organizations representing consumers and purchasers of children’s health care; ‘‘(G) national organizations and individuals with expertise in pediatric health quality measurement; and ‘‘(H) voluntary consensus standards setting organizations and other organizations involved in the advancement of evidence-based measures of health care." [Section 1139A(b)(3)]
None of these consultations occurred.
The communication to states added that CMS was exploring quality measures to capture whether parents were receiving information about the risks of immunizations and about alternative schedules.
Editors’ Note: Eliminating state reporting of vaccination coverage will make it more difficult to track changes in vaccination rates that may result from HHS policies.
