A Physician’s Warning: Ending Federal Childhood Vaccine Reporting Puts Children and Communities at Risk

According to a Centers of Medicare & Medicaid Services letter dated December 30th, 2025, state health officials will no longer be required to report childhood vaccinations to the Centers for Medicare & Medicaid Services. To some, this policy change may seem minor. However, it has the potential of having far-reaching and negative impacts on the health and well-being of our children. Specifically, the following pediatric and perinatal immunization measures will no longer be part of the 2026 Child and Adult Core Sets that are mandatorily reported to CMS:

• Childhood Immunization Status (CIS-CH)

• Immunizations for Adolescents (IMA-CH)

• Prenatal Immunization Status: Under Age 21 (PRS-CH)

• Prenatal Immunization Status: Age 21 and Older (PRS-AD)

Although not part of the reportable Core Sets, some states may voluntarily report this data to CMS.
 
I remember just a few months ago, when public health leaders advocated for preserving the recommendation to administer the initial hepatitis B vaccination to all newborn infants. Without warning, public comment, CDC advisory committee approval, or even supportive data, the Department of Health and Human Services has rescinded its recommendation that the hepatitis B vaccination be administered to healthy children of any age. The same is true for to seasonal flu, hepatitis A, meningococcal disease, rotavirus, and RSV vaccinations. Earlier in 2025, the recommendation of COVID-19 vaccination for all children was dropped, despite the vaccine having an excellent safety profile and being effective in the prevention of long COVID and hospitalizations.

Not all countries agree. Canada’s Health Minister, Marjorie Michelle, states that Canada can no longer rely on the US as a source of trusted health and scientific information “on subjects like vaccines.”

The CMS December 30^th letter also encouraged shared decision-making. This strategy has been touted as a replacement for the rescinded CMS pediatric vaccine recommendations, which were deleted from the Department of Health and Human Services’ newly truncated pediatric vaccine schedule.

However, there is no clinical equipoise in decisions about whether to receive or forgo the previously recommended pediatric vaccination. A doctor cannot ethically share in the decision not to vaccinate a child when that decision will needlessly place the child at an increased risk of death and disability. Parents may legally choose not to vaccinate their child. However, a doctor cannot ethically encourage this decision unless there are legitimate medical reasons that place the child at risk for vaccination.

Tracking the effect of new policies on vaccination rates

State- and community-level tracking and reporting of vaccination rates are critical, especially given the risk of declining rates following the implementation of the truncated pediatric vaccination schedule. Unfortunately, the data we have to this point indicates that vaccination rates are falling in the US. For example, the number of counties In the US that have vaccination rates high enough to achieve herd immunity to measles has fallen from a prepandemic level of 50% to the current level of 25%.

In an attempt to justify the newly truncated vaccination schedule, the Department of Health and Human Services points to Denmark and other peer countries. It was decided to align our vaccination schedule with the country of Denmark. But Denmark is an obvious outlier, with the fewest recommended vaccinations among developed peer countries. Unfortunately, the US has ceded its global leadership in public health and has become an outlier, similar to Denmark.

It should be noted that Denmark is a small country with a population of approximately 6 million citizens. It also has a decentralized health care system, which is universally available to citizens. In addition, it has excellent postnatal care with nurses who routinely make home visits to check on the mother and newborn period.

This one could argue that Denmark has shifted the responsibility of making recommendations from the federal to the local level. In the US, large segments of our society lack ready access to health care or primary care providers for guidance. And the number of individuals in the US without access is expected to grow with impending cuts to Medicaid, CHIP, and Affordable Care Act coverage.

Thus, if we are to reduce federal oversight and recommendations to align with Denmark’s, we should also enact universal health care. Not doing so is a grave disservice to our citizens and will not make America healthy again.

Community Level Vaccination Rates Are Important in Outbreak Response.

In response to an outbreak, knowing the community's vaccination rates against the pathogen is of utmost importance. Utilizing vaccination rate data from surrounding communities will allow prioritization for the allocation of public health resources and guide the implementation of effective ring vaccination strategies to stop the spread of the disease. For example, Deborah Birx, MD, described the importance of knowing community vaccination rates in the recent measles outbreak in Gaines County, Texas. She observed that Gaines County had a 20 per 100,000 risk of measles transmission, a level too high to achieve herd immunity. In the surrounding counties, the risk was much lower, one in 1000, which was enough to create effective herd immunity and prevent the spread of the outbreak.

Conclusion

In response to the federal government stepping back from its role in data collection and public health recommendations, local and state health departments are picking up the slack. States are forming public health alliances (the West Coast Health Alliance and the Northeast Public Health Collaborative), forming both a network and effective partners for the formulation and implementation of public health strategies. Unfortunately, not all states are participating in these efforts.

With some individual states just beginning to gear up their efforts, and the federal government all but abdicating its responsibility to make recommendations, many parents with limited access to health care are being set adrift in the quagmire of social media misinformation and AI-driven, politically biased decision-making. This is truly an unacceptable situation in a country that should be a world leader in public health and in the control of infectious diseases.