Since the COVID-19 pandemic, HR executives have paid less attention to issues around vaccines and vaccine-preventable illnesses. As 2026 begins, that is changing. Between measles outbreaks throughout the U.S. and pediatric vaccine changes announced in December 2025 and January 2026, HR teams want to know more to inform their benefits and program decisions.

Periodic updates to the list of recommended vaccines are inevitable as medical evidence matures and the landscape of infectious diseases changes. However, federal agencies announced changes this year and last that excluded the traditional input from a wide variety of medical experts. The new recommendations prompted a rapid and vigorous response from a range of medical societies, some of whom have initiated legal challenges. A federal judge has put the vaccine recommendation changes on hold and prohibited votes on future changes temporarily, although the Administration is likely to appeal.

In that setting, employers are now faced with a broad array of questions on how to respond to these changes, if at all, and how to manage this moment in time. This article will review the new federal recommendations and employer considerations in developing a response.

See also: Nearly 9 in 10 workers report satisfaction with employer-sponsored health coverage

What changed with pediatric vaccine recommendations?

The new Health and Human Services (HHS) leadership in 2025 dismissed all 17 sitting members of the Advisory Committee on Immunization Practices (ACIP) and removed the top leadership of the Centers for Disease Control (CDC).

The reformulated ACIP recommended that fewer children qualify for routine use of several vaccines, including influenza and COVID-19, and that others should either be reprioritized or delivered in a different manner. In 2025, the ACIP discontinued its universal recommendation of a birth dose of hepatitis B vaccine for newborns.

In early January, HHS made sweeping changes to the recommended vaccine schedule. The updated guidelines reduced HPV vaccination from two or three doses to one, restricted RSV, hepatitis A and B, and meningococcal vaccines to high-risk children, and shifted influenza, COVID-19 and rotavirus vaccines for normal risk children to “shared clinical decision-making” from a universal recommendation. These changes bypassed the normal review process through ACIP and the CDC.

HHS has also changed the composition of the Advisory Committee on Childhood Vaccines (ACCV), which oversees the National Vaccine Injury Compensation Program (VICP), established in 1986 to support vaccine supply in the U.S. and compensate individuals who are injured by vaccines without requiring years of litigation.

The recent changes to the ACCV may mean that more diagnoses, such as autism, could become eligible for compensation from the program. If that occurs, the VICP could run out of funds to pay claims, which would put manufacturers at risk for these claims. This may decrease the availability of current vaccines, as well as the development of future vaccines. Some manufacturers have already announced that they are discontinuing vaccine research.

What does this mean for employers?

Health plans that are compliant with the Affordable Care Act (ACA) are required to provide coverage for vaccines recommended by ACIP without cost-sharing. This requirement applies to vaccines on the CDC immunization schedule, whether the recommendation is for routine use or with shared clinical decision-making.

The changes to the childhood immunization schedule will have no impact on what childhood immunizations must be covered by ACA-compliant health plans without cost sharing. According to a HHS Fact Sheet, all immunizations recommended by the CDC as of Dec. 31, 2025, must continue to be covered without cost-sharing.

If vaccination rates decline and rates of preventable childhood illnesses increase, employers will face increased employee absences, as well as increased medical costs. The measles epidemic so far has led to hospitalizations of about one in five children infected; whooping cough cases increased by six times from 2023 to 2024, and influenza has led to over 330,000 hospitalizations and 20,000 deaths this season.

What does this mean for carriers?

We surveyed Aetna, Anthem, Cigna, Kaiser Permanente and United Healthcare in January 2026, and they all confirmed that they plan to continue to cover vaccines in alignment to an earlier 2025 version of the ACIP recommendations. Further, none of these carriers currently require that a member prove that they are high-risk, or show evidence of “shared clinical decision-making” for their fully insured clients. Continued coverage without cost sharing is currently the default for self-insured plans.

Twenty-seven states have moved to implement their own recommended immunization schedule to maintain access and coverage for these vaccinations, although state regulations generally apply only to fully insured health plans.

What was the response of the medical community?

The medical community response to the revised childhood vaccine recommendations was overwhelmingly negative. The American Academy of Pediatrics (AAP) called the revised pediatric vaccine recommendations “dangerous and unnecessary.” The Infectious Disease Society of America and over 200 other medical organizations encouraged Congress to conduct oversight of these changes that were “not based on credible evidence.”

How might these changes impact health costs for employers?

Employers are always looking for improved value and ROI for the resources they devote to the health of their employees and dependents. While many medical services are cost-effective, routine pediatric vaccines are one of the few medical interventions that are truly cost-saving at the population level.

The inevitable result of the revised pediatric guidelines is that fewer children will receive routine vaccination. Any savings from administering fewer vaccines will be more than offset by the increased costs of treating preventable communicable diseases, decreased productivity due to illness or time taking care of loved ones, and costs of clinical visits for “shared clinical decision-making.”

What can employers do at this point?

All these vaccines must be covered without cost sharing through the end of 2026. The ACA requires coverage without cost sharing even for vaccinations recommended only with shared clinical decision-making, so full coverage for these vaccines is still required.

Some employers may want to start, or continue, to promote pediatric vaccinations for their employee community. They can share credible information with their employees to educate themselves and make childhood vaccinations available under both the medical and pharmacy benefit. They can use promotional opportunities, like National Immunization Awareness Month, to highlight the benefits offered to all employees and their dependents. Employers can also request reporting on vaccination levels from their medical carriers to bring attention to this issue.

The AAP has filed a lawsuit against the revised pediatric vaccination recommendations and the current ACIP process. Lawsuits or administration actions may lead to additional changes to the national vaccine recommendations in 2026, so employers can monitor for new developments.

A look ahead

Employers play an important role in providing information and coverage benefits for their employees and dependents. Changes in federal policy heighten the importance of thoughtful employer action to protect plan members against preventable infectious diseases.

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