Impact of the Advisory Committee on Immunization Practices Recommendations on State Law

June 23, 2025

The Advisory Committee on Immunization Practices (ACIP) was formed in 1964 to “provide ongoing expert advice to the [HHS] Secretary on federal immunization policy.” Today, ACIP makes recommendations to CDC about vaccines with a focus on the control of vaccine-preventable diseases. ACIP recommendations help inform clinical and public health practice and include: “(1) the age and other population groups (e.g., by sex, occupation) recommended to receive that vaccine; (2) the recommended age or frequency to receive each dose and the interval between doses (for multidose vaccines); and (3) any precautions and contraindications.” The CDC director reviews ACIP’s recommendations and decides whether they should be formally adopted.

While ACIP recommendations are just that, recommendations and not requirements, they have a far-reaching impact on vaccine policy with nearly 600 statutes and regulations across 49 states, three territories, and Washington, D.C., referencing ACIP. These laws often direct the use or consideration of ACIP recommendations in developing or implementing state or territorial vaccine policy. If the ACIP recommendations change, then any state or territorial policy that depends on them will be altered as well.

References to ACIP recommendations appear in several different areas of vaccine policy including state and territorial laws related to:

• School immunizations.
• Mandatory insurance coverage.
• Provider scope of practice to dispense or administer vaccines.
• Required vaccine information.
• Mandatory and voluntary immunizations for health care workers and patients.
• Standing orders and protocols for dispensing or administering vaccines.
• Notifications for recommended or overdue immunizations.
• Vaccine purchasing determinations.

Immunization Requirements for School Enrollment and Attendance

State and territorial law, through statute or rule, may direct the use of or allow the consideration of ACIP recommendations when determining the jurisdiction’s vaccine requirements for school enrollment and attendance. This means any changes or deletions to the ACIP recommendations could automatically impact the jurisdiction’s school immunization laws. Some states give deference only to ACIP recommendations when determining school immunization requirements while other states include the recommendations of ACIP and other national organizations, such as the American Academy of Pediatrics (AAP), the American Academy of Family Physicians (AAFP), the American College of Obstetricians and Gynecologists (ACOG), and the American College of Physicians (ACP). The degree of adherence to ACIP recommendations also varies, with some jurisdictions requiring strict adherence to the recommendations and others taking ACIP recommendations into consideration for their vaccine policy decision making.

In Hawaii, for example, the health department “may adopt, amend, or repeal as rules, the immunization recommendations of the United States Department of Health and Human Services, Advisory Committee on Immunization Practices.” Missouri’s statute permits school enrollment when a child “has been adequately immunized against vaccine-preventable childhood illnesses specified by the department of health and senior services in accordance with recommendations of the Centers for Disease Control and Prevention Advisory Committee on Immunization Practices” while Alabama’s law provides that “vaccine doses should be administered according to the most recent version” of ACIP’s recommendations. New Mexico’s law states that “[t]he immunizations required and the manner and frequency of their administration shall conform to recommendations of the advisory committee on immunization practices of the United States department of health and human services and the American academy of pediatrics.”

Jurisdictions can identify their statutes, rules, and other policies that are tied to ACIP recommendations and assess the impact any changes to the recommendations would have on current public health practices and activities. Earlier this year, Colorado enacted HB 1027, a bill relating to school immunizations. The bill changes the source for the health department’s list of recommended school immunizations from ACIP to the state board of health and directs the board to consider ACIP recommendations as well as recommendations by AAP, AAFP, ACOG, and ACP when establishing required school immunizations, their manner, and frequency. The new law also allows the state health department to use the guidelines from AAP, AAFP, ACOG, and ACP along with ACIP when conducting its annual evaluation of immunization practices.

Required Coverage by Insurance Providers

ACIP-recommended vaccines are often required by states to be covered by Medicaid managed care organizations or private insurers. Changes to ACIP recommendations could impact the vaccines covered by these insurers.

In Delaware, a “health carrier shall provide coverage for […] immunizations for routine use in children, adolescents and adults that have in effect a recommendation from the Advisory Committee on Immunization Practices.”

Colorado enacted SB 196 giving the state insurance commissioner the ability to maintain current ACIP recommendations. The revised law states that if the ACIP recommendations “are repealed, modified, or otherwise no longer in effect, the commissioner may adopt rules to require compliance with the guidelines or recommendations that were in effect in January 2025, or that comply with the recommendations of the Nurse-Physician Advisory Task Force for Colorado Healthcare.”

Scope of Practice to Administer or Dispense Immunizations

State law may give pharmacists, pharmacy technicians, and other health care providers the legal authority to dispense or administer vaccines. The vaccines allowed under this authority are often tied to ACIP recommendations so that altering the recommendations could result in these providers no longer able to dispense or administer certain vaccines.

Maine law permits pharmacists to “administer vaccines licensed by the United States Food and Drug Administration that are recommended by the United States Centers for Disease Control and Prevention Advisory Committee on Immunization Practices, or successor organization, for administration to a person 18 years of age or older.”

In Vermont, pharmacy technicians can “only administer immunizations […] pursuant to the schedules and recommendations of the Advisory Committee on Immunization Practices’ recommendations for the administration of immunizations, as those recommendations may be updated from time to time.”

Dentists in Minnesota are permitted to give vaccinations if they “comply with guidelines established by the federal Advisory Committee on Immunization Practices relating to vaccines and immunizations.”

Requirements to Provide Information About Vaccines

In Alabama, information about the influena vaccine that schools provide parents or guardians must include “related recommendations issued by the Advisory Committee on Immunization Practices of the federal Centers for Disease Control and Prevention.”

Illinois law directs the state’s department of public health to develop an informational brochure relating to meningococcal disease that includes “the latest scientific information on meningococcal disease immunization and its effectiveness, including information on all meningococcal vaccines receiving a Category A or B recommendation from the Centers for Disease Control and Prevention’s Advisory Committee on Immunization Practices.”

In Tennessee, hospitals are directed to provide parents of newborns with educational information about pertussis and the availability of a vaccine for pertussis “in accordance with the latest recommendations of the advisory committee on immunization practices.” Tenn. Code Ann. § 68-5-110.

Oregon law requires post-secondary schools that provide housing to inform incoming students of vaccine-preventable diseases known to occur in young adults and ACIP recommendations for vaccines related to those diseases.

Vaccination of Healthcare Workforce and Patients

Some states instruct hospitals or long-term facilities to offer or require their employees and/or patients and residents certain vaccinations in adherence to ACIP recommendations.

In New Mexico, every fall and winter hospitals are required to offer older patients vaccines for influenza and pneumococcal “in accordance with the latest recommendations of the advisory committee on immunization practices.”

In Missouri, first responders who may be deployed for a bioterrorism event may be offered vaccinations for smallpox, anthrax, “and other vaccinations when recommended by the federal Centers for Disease Control and Prevention’s Advisory Committee on Immunization Practices.”

New Jersey law requires health care facilities to “establish and implement an annual influenza vaccination program in accordance with the current recommendations of the Advisory Committee on Immunization Practices.”

Regulations in Texas direct nursing homes “to offer immunizations in accordance with the most recent recommendations of the Advisory Committee on Immunization Practices.”

Standing Orders and Protocols

Indiana law authorizes the state health commissioner to issue a statewide standing order for pharmacists to administer or dispense “[a]n immunization that is recommended by the federal Centers for Disease Control and Prevention Advisory Committee on Immunization Practices for individuals who are not less than eleven (11) years of age.”

In California, the medical director at a skilled nursing facility can issue a standing order influenza and pneumococcal immunizations when the standing orders “meet the recommendations of the Advisory Committee on Immunization Practices.”

Virginia has a similar law allowing hospitals to use a standing order or protocol influenza and pneumococcal vaccinations, as long as the standing order or protocol requires “that the vaccinations be administered in accordance with the most recent recommendations of the Advisory Committee on Immunization Practices.”

Pharmacists in Iowa may, pursuant to statewide protocols developed and approved by the board of pharmacy, “order and administer […] an immunization or vaccination recommended by the United States centers for disease control and prevention advisory committee on immunization practices in its approved vaccination schedule for adults.”

Notification of Overdue Immunizations and Recommendations

California law requires schools to notify the parents or guardians of school students about the state’s advice regarding full human papillomavirus (HPV) immunization “as recommended by the Advisory Committee on Immunization Practices.”

In Colorado, the state health department may use the state’s immunization information system to contact individuals “if immunizations are due or overdue as indicated by the advisory committee on immunization practices of the United States department of health and human services or the American academy of pediatrics.”

Vaccine Purchasing

New Mexico law authorizes the state’s vaccine purchasing fund to “be used for the purchase, storage and distribution of vaccines, as recommended by the advisory committee on immunization practices.”