Recent Changes in Federal Vaccine Recommendations: What’s the Impact on Insurance Coverage?
The Trump administration has made several recent changes to federal routine vaccination recommendations. Specifically, under the auspices of Secretary Kennedy, who has long questioned the safety and efficacy of vaccines and stated his intention to review vaccine schedules, the CDC’s Advisory Committee on Immunization Practices (ACIP) has recommended changes (including to age group, type of vaccine, and/or clinical decision-making process) to seven vaccine usage recommendations in the United States: Meningococcal; RSV for adults; RSV for children; influenza; COVID-19; Measles, Mumps, Rubella and Varicella (MMRV); and Hepatitis B. These recommendations, which have been adopted by the HHS Secretary or Acting CDC Director, have raised questions about the implications for insurance coverage, since most insurers are required to cover ACIP/CDC recommended vaccines at no-cost, either due to requirements of the Affordable Care Act or other federal statutes.
Below, we provide an overview of each of these changes and what they mean for coverage requirements. As the table indicates, of the seven recent changes, two have no implications for coverage, two removed the coverage requirement, and three expanded the requirement. When a coverage requirement is removed, an insurer could still choose to cover a vaccine at no cost. In fact, AHIP, the trade association for the health insurance industry whose members cover more than 200 million Americans, announced that health plans will continue to cover all ACIP-recommended immunizations that were recommended as of September 1, 2025 with no cost-sharing for patients through the end of 2026. When a coverage requirement is expanded, insurers (with limited exception) must cover the vaccine at no-cost. The insurance requirement extends to vaccines with “individual decision-making” (also known as “shared clinical decision-making”) recommendations as well, which are those “individually based and informed by a decision process between the health care provider and the patient or parent/guardian”.
In addition to federal requirements for coverage, states have the authority to require state-regulated health insurers (employer plans that are fully insured and individual and small-group marketplace plans) to cover vaccines beyond minimum federal requirements (and not necessarily linked to current ACIP/CDC recommendations). As of December 2025, eight states have moved to do so (and one state authorizes the state Commissioner of Insurance to do so). Still, states cannot impose coverage requirements on self-insured employer plans, which cover most (67%) people with employer coverage.
Additional changes to ACIP-recommended vaccine schedules are likely, as President Trump has issued a Presidential Memorandum calling on HHS and CDC to begin a “process to align U.S. core childhood vaccine recommendations with best practices from ‘peer, developed countries’”. Beyond their implications for insurance coverage, changes to vaccine recommendations, particularly those that narrow or limit access, are likely to have other implications, such as driving down already falling vaccine coverage rates in the United States.
Changes to Vaccine Recommendations and Insurance Coverage
| Vaccine | Prior Recommendation | New Recommendation | Date of Change | Insurance Implications |
| Meningococcal | MenACWY and MenB may be administered at the same visit if indicated (for certain populations). | MenABCWY vaccine may be used when both MenACWY and MenB are indicated at the same visit (for certain populations). | 4/16/25 (ACIP) 6/25/25 (HHS) | Expands coverage requirement to include new pentavalent (5-in-1) MenABCWY vaccine for those indicated. Applies to private insurers, Medicaid, Vaccines for Children Program. |
| RSV for adults | Recommended for all adults, ages 75 and older and adults ages 60-74 with increased risk. | Recommended for all adults, ages 75 and older and adults ages 50-74. | 4/16/25 (ACIP) 6/25/25 (HHS) | Expands coverage requirement to include those ages 50-59 who are at increased risk. Applies to private insurers, Medicaid, Medicare Part D. |
| RSV for children | Recommended that infants aged < 8 months born during or entering their first RSV season who are not protected by maternal vaccination receive nirsevimab. | Recommended that clesrovimab, a monoclonal antibody approved in 2025, be added as an option, with no preferential recommendation between nirsevimab and clesrovimab. | 6/25/25 (ACIP) 7/22/25 (HHS)
| Expands coverage requirement to include new monoclonal antibody for infants. Applies to private insurers, Medicaid, Vaccines for Children Program. |
| Influenza | Single-dose and multi-dose influenza vaccines recommended | Multi-dose influenza vaccines with Thimerosal no longer recommended | 6/25/25 (ACIP) 7/22/25 (HHS) | Removes coverage requirement for multi-dose flu vaccine (which will no longer be available in the U.S. market). Applies to private insurers, Medicaid, Vaccines for Children Program. Medicare Part B required to cover by statute, not linked to ACIP/CDC*. |
| COVID-19 | Recommended for everyone, ages 6 months and older | Vaccination based on individual-based decision-making (also known as shared clinical decision-making) with an emphasis that the risk-benefit of vaccination is most favorable for individuals who are at an increased risk for severe COVID-19 disease and lowest for individuals who are not at an increased risk. | 9/19/25 (ACIP) Last week of September (CDC)
| Coverage requirement remains unchanged (vaccines recommended through individual-based decision-making must be covered at no-cost). Applies to private insurers, Medicaid, Vaccines for Children Program. Medicare Part B required to cover by statute, not linked to ACIP/CDC. |
| Measles, Mumps, Rubella, Varicella | Both the combined measles, mumps, and rubella (MMR) vaccine and combined measles, mumps, rubella, and varicella (MMRV) vaccine recommended for children | Recommendation that Varicella vaccine be given as stand-alone vaccine (combined MMRV no longer recommended) | 9/19/25 (ACIP) Last week of September (CDC) | Removes coverage requirement for combined MMRV. Applies to private insurers, Medicaid, and Vaccines for Children Program. |
| Hepatitis B | Birth dose recommended for all infants | Vaccination based on individual-based decision-making for parents deciding whether to give the hepatitis B vaccine, including the birth dose, to infants born to women who test negative for the virus. For those infants not receiving the birth dose, recommendation that initial dose be administered no earlier than two months of age. Additionally, when evaluating need for subsequent dose in children, recommended that parents should consult with health care providers to decide whether to test first. | 12/5/25 (ACIP) 12/16/25 (CDC, change in birth dose recommendation adopted; review of screening recommendation still underway) | Coverage requirement remains unchanged (vaccines recommended through individual-based decision-making must be covered at no-cost). Applies to private insurers, Medicaid, Vaccines for Children Program. Medicare Part B required to cover by statute, not linked to ACIP/CDC. |
Notes: See KFF, ACIP, CDC, and Insurance Coverage of Vaccines in the United States, for coverage criteria by payer. *While Medicare Part B is required to cover influenza vaccine by statute, not linked to ACIP/CDC, this change will result in the removal of the multi-dose vaccine from the market.
Sources:
- https://www.cdc.gov/acip/vaccine-recommendations/index.html
- https://www.cdc.gov/acip/vaccine-recommendations/index.html#:~:text=RSV%20Vaccines%20%2D%20Adults
- https://www.hhs.gov/press-room/acip-recommends-covid19-vaccination-individual-decision-making.html
- https://www.hhs.gov/press-room/thimerosal-mercury-removed-from-us-flu-vaccines-acip.html
- https://www.hhs.gov/press-room/cdc-immunization-schedule-individual-decision-covid19-standalone-chickenpox-toddlers.html
- https://www.hhs.gov/press-room/acip-recommends-chickenpox-vaccine-for-toddlers.html
- https://www.hhs.gov/press-room/acip-recommends-individual-based-decision-making-hepatitis-b-vaccine-birth-dose-infants-born-women-test-negative-virus.html
- https://www.hhs.gov/press-room/cdc-adopts-individual-based-decision-making-for-hepatitis-b-immunization-for-infants-born-to-women-who-test-negative-for-the-hepatitis-b-virus.html