States Won't Have to Report Childhood Vaccination Levels: An Infection Preventionist’s Response

Reading, “states will no longer have to report how many children they vaccinate to the Centers for Medicare & Medicaid Services (CMS)” in a December 30, 2025, letter to state health officials, caused an immediate air of concern.¹ State reporting requirements matter in infection prevention and control (IPC) because it ensures accurate, transparent, and usable data for evidence-based decisions, fostering public trust, and guiding policy.

While the casual reviewer of this heading may deem this as just one less task for health care professionals, IPC professionals will be left without invaluable data to substantiate past, current, or even future immunization schedules. Over 40% of children younger than 6 years old are covered by Medicaid and Children's Health Insurance Program (CHIP), CMS, and state health departments previously used the Core Sets of Health Quality Measures to track the quality of healthcare provided by these programs.² Without requiring this data, there is a looming fear that there will be less of a prioritization of immunizations, which will inevitably lead to an uptick in outbreaks of vaccine-preventable diseases.

An increase in vaccine-preventable diseases is arguably rooted in declining vaccination rates linked to various factors such as vaccine hesitancy, disrupted health services, access issues in low-income areas, and underfunding of public health programs. There is already evidence of lower community (herd) immunity with a resurgence of diseases such as measles. The recent change to CMS reporting requirements, coupled with reduced universal recommendations for vaccines such as the flu shot, is fueling significant infection prevention concerns and increasing vaccine hesitancy among parents and healthcare providers.

The Advisory Committee on Immunization Practices (ACIP) states, “Unlike routine, catch-up, and risk-based recommendations, shared clinical decision-making vaccinations are individually based and informed by a decision process between the health care provider and the patient or parent/guardian.”³

However, a large share of Americans are confused by the idea of “shared clinical decision-making,” according to the August 2025 and December 2025 surveys from the Annenberg Public Policy Center (APPC).⁴ These surveys were conducted as a result of the CDC's decision to move COVID-19 vaccines to a “shared clinical decision-making” model, which coincided with low uptake and confusion at pharmacies and clinics across the country.

The untimely elimination of the CDC’s Healthcare Infection Control Practices Advisory Committee (HICPAC) has cleared the landscape of a once-robust culture of coordinated, multidisciplinary alignment on infection prevention and control, leaving space for potential variations and inconsistencies in organizational policies and clinical practices.

I have been able to find a sense of optimism among these significant changes as the Association for Professionals in Infection Control and Epidemiology (APIC) and the Society for Healthcare Epidemiology of America (SHEA) have announced a new collaborative initiative, the Healthcare Infection Prevention Advisory Group (HIPAG), to address infection prevention priorities of national importance.⁵ It appears that HIPAG will help fill the gaps created by the loss of HICPAC and ensure that national infection prevention discussions reflect the full gamut of expertise required to provide science-driven, practical, evidence-based infection prevention policies.

Until the newly announced HIPAG is in full swing, infection preventionists all over America will have to juggle implementing or even proposing practices with limited data. In the broader context, patients, public health officials, and health care professionals are all plagued by misinformation that could make long-standing practices such as vaccination schedules obsolete.  

References:

1. 2027 Updates to the Child and Adult Core Health Care Quality Measurement Sets and Mandatory Reporting Guidance. Centers for Medicare & Medicaid Services; US Department of Health & Human Services. 2025. Accessed January 13, 2026. https://www.medicaid.gov/federal-policy-guidance/downloads/sho25005.pdf
2. Georgetown University Center for Children and Families. Analysis of US Census Bureau 2023 American Community Survey Public Use Microdata Sample. Published 2024. Accessed January 13, 2026. https://ccf.georgetown.edu/2025/01/14/medicaid-coverage-in-metro-and-small-town-rural-counties-2023/
3. ACIP Shared Clinical Decision-Making Recommendations. CDC. Updated 2024. Accessed January 13, 2026. https://www.cdc.gov/acip/vaccine-recommendations/shared-clinical-decision-making.html
4. Center for Infectious Disease Research and Policy (CIDRAP). Confusion surrounds CDC’s shared clinical decision-making paradigm for childhood vaccines. Published 2023. Accessed January 13, 2026. https://www.cidrap.umn.edu/childhood-vaccines/confusion-surrounds-cdc-s-shared-clinical-decision-making-paradigm-childhood
5. Association for Professionals in Infection Control and Epidemiology. APIC and SHEA announce joint Healthcare Infection Prevention Advisory Group (HIPAG). Published 2023. Accessed January 13, 2026. https://apic.org/news/apic-and-shea-announce-joint-healthcare-infection-prevention-advisory-group-hipag/