NCSL - National Conference of State Legislatures

02/26/2026 | Press release | Distributed by Public on 02/26/2026 10:46

States Weigh Their Options as Feds Upend Vaccine Policy

States Weigh Their Options as Feds Upend Vaccine Policy

From access and cost to school requirements, exemptions and parental rights, states are going their own ways.

By Kelly Hughes | February 26, 2026

Federal guidelines issued in January reduced the number of universally recommended childhood vaccines from 17 to 11. (People Images/Getty Images)

Vaccine policy remained an active area of legislation in 2025, with numerous states and federal agencies updating laws, regulations and guidance related to access, coverage, requirements and public health authority.

At the federal level, Health and Human Services Secretary Robert F. Kennedy Jr. replaced all sitting members of the committee that helps develop vaccine policy for the Centers for Disease Control and Prevention. The Advisory Committee on Immunization Practices, or ACIP, reconstituted with advisors named by Kennedy, then altered vaccine usage recommendations. The CDC also issued a childhood immunization schedule that reduced the number of covered diseases from 17 to 11 and routine vaccines from 13 to seven.

Legislative Activity

Lawmakers from 49 states, Washington, D.C., and Puerto Rico introduced at least 532 vaccine-related bills in 2025, an increase from 433 in 2024. About 9% of the bills became law, similar to the previous year. States pursued a wide range of approaches focused on:

  • Access, coverage and cost.
  • School requirements and exemptions.
  • Provider scope of practice and workforce capacity.
  • Parental rights, recommendations, authority and public health messaging.

Related: Find more on vaccine bills in the State Public Health Legislation Database.

Access, Coverage and Costs

Several states enacted laws intended to make immunizations more accessible or affordable and addressed funding vaccines through fees. Maryland and New Mexico required insurance plans to cover recommended immunizations without cost-sharing. Arkansas directed its Medicaid program to establish administration fees for immunizations and monoclonal antibody treatments for respiratory syncytial virus, or RSV. Louisiana increased the maximum fees that may be charged for certain services, including childhood vaccination visits, at parish health units.

Hawaii established a universal immunization funding program, which provides state-purchased access to recommended immunizations to children and adults, and dedicated funding to help residents not eligible for no-cost vaccines through existing programs.

States also considered measures to expand vaccine availability. Georgia extended influenza vaccination offers to younger hospital patients. Maine expanded its universal immunization program to adults.

School Requirements and Exemptions

Routine childhood vaccination rates have declined since the start of the COVID-19 pandemic, and certain types of school exemptions have increased. In 2025, states adopted a variety of administrative and procedural changes regarding school vaccine requirements. Alabama allowed military medical records to serve as acceptable documentation for school immunization requirements. Utah streamlined immunization record transfers and removed expiration dates for exemption forms.

Colorado adjusted administration of its school immunization laws, including the removal of fixed grace periods and an extension of school reporting timelines. Illinois eased documentation requirements for postsecondary students unable to obtain complete vaccine histories.

States also changed their exemption and opt-out policies. North Dakota created formal opt-out procedures for health, religious or philosophical reasons across school and child care settings. Iowa required schools to publicly post information on vaccine exemptions on their websites. Texas simplified its process for requesting nonmedical exemptions. Tennessee exempted fully online, self-paced private schools from certain vaccination requirements. Idaho transferred authority over school vaccination requirements from the executive branch to the Legislature.

Provider Scope of Practice and Workforce Capacity

As in previous years, states continued to pursue strategies to expand vaccination workforce capacity by adjusting professional scope of practice. Hawaii, Maryland, Nevada and New Jersey expanded or clarified the authority of pharmacists, interns and technicians to administer vaccines, often with training and reporting requirements. Colorado authorized dentists to provide certain vaccinations. Oregon extended vaccine administration to physical therapists. Arkansas permitted advanced practice registered nurses to delegate certain routine immunization tasks to medical assistants and other unlicensed personnel.

Parental Rights and Public Health Messaging

Several states enacted legislation related to parental consent or public health communication. Alabama raised the minimum age at which minors may independently consent to most health care from 14 to 16. Texas required written parental or guardian consent for COVID-19 vaccination of minors.

Tennessee mandated that public health communications about FDA-approved products-including vaccines, masks and products authorized for emergency use-be based on verified data and scientific research. The law directs state public health agencies to avoid unverified claims or language that could be interpreted as promotional.

Other states, including Florida, Idaho and Montana, enacted limitations on vaccine mandates and related public health measures. Legislation in Montana, Tennessee and Texas prohibited discrimination based on vaccination status in certain settings. Texas also enacted legislation related to liability standards for vaccine manufacturers.

At least 22 states incorporated guidance from entities other than the federal government, either in addition to or instead of CDC/ACIP recommendations, according to KFF. In 2025, California and Washington, D.C., enacted changes to existing statutes referencing ACIP recommendations, and New Mexico now requires immunization rules for children to be based on the recommendations of its health department or the American Academy of Pediatrics.

Looking Ahead

In 2025, the U.S. recorded the highest number of measles cases in three decades, according to the AAP, and the highest number of pediatric flu deaths since the CDC began nationwide tracking in 2004. Public health officials continue working to maintain the nation's measles elimination status, which has come under pressure amid ongoing transmission.

Vaccine policy is expected to remain an active legislative issue as states assess federal changes and respond to local public health considerations.

NCSL tracks vaccine legislation in the State Public Health Legislation Database.

Kelly Hughes is an associate director in NCSL's Health Program.

This work was supported by the Centers for Disease Control and Prevention of the U.S. Department of Health and Human Services as part of a financial assistance award totaling $200,000 with 100% funded by CDC/HHS. The contents are those of the authors and do not necessarily represent the official views of, nor an endorsement by, CDC/HHS or the U.S. government.

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