Children from low-income families, those without health insurance or who are under-insured, as well as Native American children, have long had access to life-saving vaccines through the Vaccines for Children (VFC) program, established decades ago as part of Medicaid. However, that access is under threat by the Trump administration due to the actions of Secretary of Health and Human Services (HHS) Robert F. Kennedy Jr. (RFK Jr.), a longtime vaccine skeptic.
RFK Jr. recent actions cast doubt on his Senate confirmation commitment to “maintain the Centers for Disease Control and Prevention’s Advisory Committee on Immunization Practices (ACIP) recommendations without changes,” when he purged ACIP, replacing them with hand-selected appointees widely viewed as unqualified. As the key advisory group at HHS’s Centers for Disease Control and Prevention (CDC), ACIP has long followed a rigorous, evidence-based process to develop recommendations for childhood and adult immunizations. That well-considered, deliberative process has apparently ended, for now.
ACIP’s recent meeting, which took place between September 18 and 19, descended into false claims, confusion, and acrimony. The panel ultimately voted to remove its recommendation for the combined measles, mumps, rubella, and varicella (MMRV) vaccine for young children, contrary to the recommendations of the American Academy of Pediatrics (AAP) and other medical professionals. Although separate MMR and varicella vaccines will still be recommended for this group, ACIP indicated that it would review all other vaccine recommendations in future meetings.
For now, it appears the vote will likely not impact children receiving care through private insurance. The trade group representing commercial insurers, AHIP, issued a statement that health plans would continue covering immunizations in place as of September 1, 2025, reaffirming its commitment to immunization coverage grounded in “rigorous review of scientific and clinical evidence.” Additionally, numerous states have enacted laws and policies requiring insurance coverage recommended by independent medical organizations like the American Academy of Family Physicians (AAFP) and AAP, given the loss of confidence in ACIP.
However, children in low-income families and those who are underserved may be directly impacted because Congress tied ACIP recommendations to coverage in the VFC program. On October 6, the CDC formally adopted the ACIP’s recommendation to remove the combined MMRV vaccine for children under age 4 from its immunization schedule for children and adolescents, which now will no longer be provided to these children under the VFC program. This portends future changes to ACIP recommendations under RFK Jr., which would turn back the clock on advances in childhood immunization under VFC and Medicaid, with children from low-income families bearing the brunt of harm.
Although Medicaid has long covered childhood immunization under the Early and Periodic Screening, Diagnostic and Treatment (EPSDT) benefit, immunization rates varied widely, largely due to access barriers. Congress established the VFC program in 1993 in response to a measles outbreak among unvaccinated children, creating a framework whereby HHS purchases ACIP-recommended vaccines in bulk from manufacturers and distributes them to states and providers. The VFC program has prevented an estimated 472 million illnesses and saved nearly $2.2 trillion in health care costs. However, if the ACIP continues on this road of removing proven vaccines from its child and adolescent immunization schedule, these gains may disappear as VFC coverage is becomes more limited, access impeded, and vaccine hesitancy grows.
Congress made immunizations a mandatory service as part of EPSDT in the 1970s, and later tied coverage “at minimum” to ACIP-recommended vaccines. However, state Medicaid programs can go beyond the minimum and cover non-ACIP vaccines. In guidance documents issued in 2023 and 2024, HHS noted “non-ACIP-recommended vaccines and vaccine administration are covered for beneficiaries eligible for EPSDT, if the service is determined to be medically necessary for the beneficiary based on an individualized assessment and state medical necessity criteria.”
Despite the federal government’s authorization to provide non-ACIP vaccines, state Medicaid programs may still struggle to make these vaccines easily accessible. One of the chief advantages of VFC — low cost in purchasing of vaccines, and the ability of providers to keep vaccines in stock — may be lost if RFK Jr.’s ACIP guts the current recommendations. States also may need to establish new mechanisms to purchase and administer vaccines outside VFC, which might require a state plan amendment (SPA), and approval from the Centers for Medicare & Medicaid Services (CMS). And while states could elect to use state-only dollars to pay for services not covered with federal Medicaid funds, this is unlikely given severe budget constraints facing many states.
If ACIP’s September meeting is any indication, the future of vaccine access under RFK Jr. will be marred by confusion, chaos, and eventually coverage losses. If ACIP recommendations diverge from those of reputable medical professional groups like AAP, state coverage and access become more challenging. Those who will be most harmed will be low-income and underserved children who have greatly benefitted from the free and easily accessible immunizations provided under the VFC program, further widening the health inequities between rich and poor in this country.
This post is part of a blog series on coverage of preventive services in the face of recent HHS actions:
- RFK Jr.’s new regime puts vaccine coverage for low-income children in jeopardy
- California takes bold action to protect access to preventive services
- COVID-19 vaccine blog. (Coming soon)
