The CDC has unilaterally changed the national recommended childhood immunization schedule to nearly match Denmark’s, reducing the number of fully recommended vaccines from 17 to 11.
The decision follows a directive from President Trump to review the vaccine schedules of other high-income countries and assess the U.S. schedule based on current scientific evidence. However, infectious disease, pediatric, and other public health experts said the change does not accurately reflect the actual evidence base and will have substantial public health implications that journalists will need to explain to their audiences.
Because this decision was made so suddenly, without appearing to follow proper procedures and channels, AHCJ has assembled this tip sheet to help journalists report on this development. Some questions remain open-ended, such as the extent to which this move is legal and how legislators or courts might disrupt or delay it — all of which may be addressed in a future post.
This tip sheet can help reporters educate their audiences on what this change means, starting with key points to convey and followed by answers to relevant questions.
Key points for journalists to highlight in their coverage
- Contrary to the claims of this administration and its appointed public health officials, the newly adopted schedule does not align with the most up-to-date evidence base on the vaccines U.S. children need to avoid infectious diseases. Consult expert sources and organizations noted here for quotes and data.
- The AAP has its own recommended childhood immunization schedule, which adheres to the most current evidence-based vaccine research and is identical to the CDC schedule that was in effect before Trump’s second term.
- The AAP and other major medical and public health organizations oppose this schedule change, as they have with other non-evidence-based changes the CDC and HHS have made to federal vaccine policy. These organizations support the previous (2024) schedule as the safest and most effective way to protect U.S. children from infectious diseases and say the new schedule poses substantial public health risks. Board-certified pediatricians and family physicians following the best evidence on vaccines are likely to continue recommending and following the previous CDC/current AAP schedule.
- Denmark’s population demographics, infectious disease risks, public health approach, and health care system are dramatically different from those in the U.S. (See helpful links at the bottom for articles outlining specific ways the two differ that audiences should understand.)
- The HHS memorandum is riddled with scientific inaccuracies, misrepresented research and false statements about the safety and effectiveness of vaccines.
- The legality of the change is uncertain and likely to be challenged.
- Many individual states are likely to follow the AAP schedule instead of the CDC schedule, as they did with the change to the hepatitis B vaccine birth dose. Further, some state legislatures are considering laws to de-link their vaccine laws from ACIP recommendations.
- There will be substantial administrative costs to health providers, payers, and local, county, state, and federal governments to change paperwork associated with these changes.
- The most immediate ramifications of this change will likely be confusion among families and providers and an increase in vaccine hesitancy and refusal. Long-term ramifications are likely to include increased infections and outbreaks, particularly of the more contagious diseases like rotavirus and meningitis.
What changes were made to the schedule?
The new schedule keeps universal recommendations for vaccines against measles, mumps, rubella, diphtheria, tetanus, pertussis, polio, Haemophilus influenzae type B (Hib), pneumococcal disease, human papillomavirus (HPV), and varicella (chickenpox). The chickenpox vaccine is the only one of these that Denmark does not recommend. The new schedule shifts vaccines for hepatitis A, hepatitis B, rotavirus, meningococcal disease, influenza, and COVID-19 from universally recommended to “shared clinical decision-making.”
What is shared clinical decision-making and what does it mean?
You can read more about shared clinical decision-making recommendations at this archived CDC page and in this article by a law professor who specializes in vaccine law. In short, it means that, instead of universally recommending a vaccine to all children, the CDC recommends families and providers discuss individual risks and benefits of the vaccine and disease and individual health circumstances before deciding whether to get the vaccine. However, it’s important to note that parents have always had the right to refuse any vaccine.
A shared clinical decision-making recommendation does not change whether a vaccine qualifies for the Vaccine Injury Compensation Program, and the vaccines will continue to be available and legally required to be covered in full by private insurance, Medicaid, the Children’s Health Insurance Program (CHIP) and the Vaccines for Children Program.
How precisely did this change occur?
The President issued a memo in December directing the CDC to examine the current recommended childhood vaccine schedule. Trump and HHS Secretary Robert Kennedy Jr. expressed an interest in adopting the Danish schedule, despite the current U.S. schedule having a lengthy safety record.
Typically, changes to the immunization schedule are discussed and voted on in a mandatory public meeting of the Advisory Committee on Immunization Practices, which must announce its meetings in advance and accept public comments. Instead of following traditional bureaucratic procedures, Deputy Secretary of Health and Human Services Jim O’Neill, who is also the acting director of the CDC, signed a memorandum from NIH Director Jay Bhattacharya, Centers for Medicare and Medicaid Services director Mehmet Oz, and FDA Commissioner Marty Makary that asked the agency to adopt a new schedule.
Is this change legal?
Whether this change is legal is complicated, according to Dorit Reiss, professor of law at UC Law San Francisco. “The Secretary has the authority to change the recommendations under Supreme Court jurisprudence,” she said, “but there are several real problems here.” One is a process issue: The public health officials allege that ACIP discussed changing the schedule, but no ACIP vote occurred on the overall schedule or the six vaccines with new recommendations. “I think the requirement of going through ACIP actually requires a vote,” Reiss said.
In addition, the administration has not provided a scientifically or legally sound explanation for the change. “To withstand ‘arbitrary and capricious review,’ they need to explain why they did it well enough, and why they think a change from previous policy is justified,” Reiss said. “I don’t see that in the materials. Their cowardliness — not expressly saying they’re following Denmark, where it’s clear they are — may work against them as well. They do not explain what are ‘peer countries,’ why they’re peer, [or] why it’s justified in any meaningful way.”
The change is likely to face legal challenges, including potentially an additional lawsuit from the AAP, which is already suing Kennedy for vaccine policy changes and HHS for canceled grants.
What is HHS’s justification for the change?
The HHS memo inaccurately suggests that there are significant safety gaps in the existing vaccines and schedule. It also suggests, without citing the evidence, that reducing recommended vaccines will restore declining trust in vaccines.
The memo neglects to mention that the U.S. has been a leader in determining which vaccines to recommend and that most countries require more vaccines than Denmark. It notes declines in infectious diseases as justification for changing recommendations to their vaccines when the declines were due to the use of those vaccines. Journalists should consult local and national experts for additional comments on inaccuracies and misrepresentations in the memo.
For accurate information on the six diseases with changed recommendations, consult only CDC pages archived prior to January 2025, the website of the Infectious Disease Society of America, individual foundations specific to particular diseases (such as the Hepatitis B Foundation and the Meningitis Research Foundation), and other reliable sources previously recommended by AHCJ.
Helpful links
- Where to find accurate vaccine information amidst the CDC’s ongoing collapse, AHCJ
- AAP Opposes Federal Health Officials’ Unprecedented Move to Remove Universal Childhood Immunization Recommendations, American Academy of Pediatrics
- AAP’s Recommended Child and Adolescent Immunization Schedule for Ages 18 Years or Younger
- IDSA statement on childhood vaccine schedule, Infectious Disease Society of America
- The HHS memo outlining justifications for the change
- There’s Something Rotten In The United States: Why the Denmark Vaccine Schedule Won’t Work in the U.S., Unbiased Science
- Why Denmark’s vaccine schedule works for Denmark — but not for the United States, STAT Opinion
- R.F.K. Jr. Likely to Swap U.S. Childhood Vaccine Schedule for Denmark’s, NYT
- Why Adopting Denmark’s Vaccine Schedule Would Be Dangerous for American Children, Jake Scott, M.D.
- “Best practices”: The buzzword that the Trump administration will use to eliminate as many vaccines as RFK Jr. can, Science-Based Medicine
