Downstream Effects of CDC Adopting ACIP Recommendations for COVID-19 and MMRV Vaccines
October 07, 2025 | Susan Kansagra, Andy Baker-White, Meredith Allen, Kimberly Martin, Ericka McGowan
On Oct. 6, CDC adopted the recommendations that the Advisory Committee on Immunization Practices (ACIP) made in September — specifically, individual-based decision-making for COVID-19 vaccine and separate measles, mumps, and rubella vaccine, and the varicella vaccine in toddlers.
The adoption of these recommendations now sets in motion a cascade of other processes that influence access to vaccines. In addition, several states have begun to examine how their state level policy and laws intersect with ACIP recommendations given the delay in adoption and the uncertainty of the process going forward.
COVID-19 Vaccine Recommendation
CDC adopted the recommendation for shared clinical decision-making for the COVID-19 vaccine for those six months and older. The adoption of this ACIP recommendation has a ripple effect on coverage and access:
- It enables states to begin ordering COVID-19 vaccine under the Vaccines for Children program.
- It allows state Medicaid programs that link coverage to ACIP recommendations to cover the cost of the vaccine.
- It enables pharmacists to provide the COVID-19 vaccine under the federal PREP act declaration — as opposed to or in addition to state law, which varies by state. Many state health departments issued standing orders and executive orders to enable pharmacists to administer in the meantime.
- It requires health insurers to cover the cost of the vaccine, as the Affordable Care Act ties insurance coverage requirements to ACIP recommendations. Though, prior to the meeting, health insurers indicated they would do so anyway this year.
MMRV Recommendation
The CDC also adopted the recommendation for separate varicella (V) and measles, mumps, rubella (MMR) vaccines rather than the MMRV vaccine (combined measles, mumps, rubella, varicella) for children under four years.
As background, current guidance allows either MMRV or MMR + V to be administered to children 12-47 months. However, because of a small but higher risk of febrile seizures for dose one, they are recommended to be administered separately (MMR + V), unless families express a preference for MMRV. Only about 15% of children currently receive MMRV for the first dose, and the general consensus is that this decision will result in some changes but not significantly impact access to vaccines:
- The adoption of this recommendation means that VFC will no longer cover MMRV for children under four, but it continues to cover separate MMR and V vaccines.
- Since many state Medicaid plans tie vaccine coverage to ACIP recommendations, coverage of MMRV by state Medicaid will vary depending on this language, though separate MMR and V vaccines would continue to be covered.
- Private insurers can choose to cover MMRV and will likely continue to in the short term but are not required to. They are required to cover separate MMR and V vaccines.
How States Are Preparing for the Future
As it stands now, ACIP recommendations, particularly for respiratory viral season, are not that different than prior years – with influenza, RSV, and the COVID-19 vaccine recommended (the latter with shared clinical decision making). However, the delayed and unpredictable process has led many states to examine how closely they are tied to ACIP in law, regulation, or practice.
Over 600 statutes across U.S. states and territories reference ACIP — whether for pharmacist vaccine authority, school entry, health care worker or other requirements. States have considered a variety of actions to ensure they maintain access to vaccinations for their jurisdictions including:
- Passing or introducing legislation that allows the state health department to use ACIP guidance from previous years or recommendations from other bodies (e.g., medical provider organizations) in state law, as it relates to school entry, pharmacist authority, and others.
- Issuing standing orders and executive orders to enable pharmacists to administer vaccines in the absence of ACIP recommendations.
- Examining Medicaid state plan language to determine how to interpret requirements when ACIP is referenced and considering updates to that language (e.g., North Carolina).
- Issuing state requirements for insurers on vaccine coverage (e.g., Oregon, California, Hawaii).
- Examining use of state funds to purchase vaccines.
Supplemental Resources
- Tracking State Actions on Vaccine Policy and Access by KFF
- Vaccine Resources by the Common Health Coalition
- States Take Action to “Immunize” Vaccine Access by Mandy Cohen, Julian Polaris, and Liz Dervan
- Vaccine Integrity Project — Fall Immunization Information by the Center for Infectious Disease Research and Policy
Special thanks to Kimberlee Wyche Etheridge, MD, MPH, for her review.