A Request for Information (RFI) filed on Friday by the Department of Health and Human Service (HHS) asks for public comment on whether current federal categories for vaccinations are “adequate.”
Vaccines are categorized as routine (universal), risk-based or shared clinical decision-making (SCDM).
“The Department seeks comment on these categories and whether additional or different categories should be adopted,” the RFI states.
As the document notes, SCDM was adopted by the Advisory Committee on Immunization Practices for the Centers for Disease Control and Prevention in 2019. SCDM applies to vaccines are those that a provider and patient can discuss and decide whether they would have benefits for that individual.
In his executive order earlier this month, Trump called for moving certain childhood vaccines from being universal to being either risk-based or SCDM, reducing the number of routine immunizations from 18 to 11.
Health care attorney Richard Hughes IV blasted the RFI in a memo Friday.
“Whether or not the development of the SCDM category is considered beneficial, considerable ACIP deliberation went into its creation. Under the guise of simply requesting information, the administration is now making clear its intent to modify existing recommendation categories, or even create new ones,” wrote Hughes.
“Perhaps even more troubling is what the RFI does not say. It makes no mention of ACIP, the body charged with developing vaccine recommendations since 1964, whose recommendations are the indispensable legal trigger for ACA coverage mandates, VFC program scope, EPSDT obligations, Medicare Part D zero-cost-sharing, and pharmacist scope-of-practice authority across dozens of states,” he added.
The public can submit comments until September 20, 2026.
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