The Advisory Committee on Immunization Practices meets in Atlanta on September 18–19, 2025 to review the immunization schedules for several vaccines.
Normally, ACIP is made up of medical and public health experts who carefully review evidence and make recommendations to protect public health. But earlier this year, Secretary Kennedy removed those qualified members and replaced them with anti-vaccine activists and wellness influencers.
This change matters a lot. ACIP recommendations guide both federal and state rules about who gets access to vaccines, which vaccines must be covered with no out-of-pocket costs, and even who is allowed to give shots.
On the table later this month are several vaccines: COVID-19, RSV, MMRV, and Hepatitis B. For now, let’s focus on COVID-19, because access to that vaccine could shrink dramatically depending on what ACIP recommends.
If ACIP only recommends the COVID-19 vaccine for people over 65 and a small group of younger adults with certain high-risk medical conditions, then insurance companies won’t have to cover the shot for everyone (per the Affordable Care Act).
Pharmacists in Arizona would also lose the ability to give the vaccine to most people without a prescription. This would create real barriers for people who want protection from COVID-19, especially those who are used to the convenience of getting vaccinated at a pharmacy.
Fortunately, Arizona has some options to step in and protect access.
First, AHCCCS, Arizona’s Medicaid program, which covers nearly 2 million people, could make an administrative decision to cover the COVID-19 vaccine for all members.
There’s precedent for this kind of action. During the H1N1 outbreak, AHCCCS made a similar decision to ensure widespread access to vaccines. If AHCCCS takes this step again, it would go a long way toward keeping vaccines available.
Another possibility is through regulating private insurance. The Arizona Department of Insurance and Financial Institutions may have the authority to require private insurance companies to cover the COVID-19 vaccine, even if (when) ACIP narrows its recommendation. If that authority is clear, DIFI may be able to make sure Arizonans with commercial insurance don’t lose coverage for that vaccine.
Pharmacy access is also a critical issue. Most Arizonans now rely on their local pharmacy for vaccines. But under state law (ARS 32-1974), pharmacists can only give vaccines to groups recommended by ACIP, unless action is taken at the state level.
There are two tools at the state level. The ADHS could publish its own list of vaccines that pharmacists can give without a prescription [ARS 32-1974(H)]. Because ADHS is exempt from the normal rulemaking process under that statute, it could be done pretty quickly, within a matter of months.
In the meantime, the ADHS Chief Medical Officer or county health officers could also issue what’s known as a “standing order.” This works like a blanket prescription that applies to entire groups of people, allowing pharmacists to continue giving the COVID-19 shot to the broader population.
These options could mitigate the damage caused by a restrictive ACIP recommendation when they meet later this month. It’ll require coordination and swift action across agencies (and of course leadership & support from the Governor), but it’s possible.
ACIP’s September meeting could make it much harder for Arizonans to get COVID-19 vaccines and maybe even RSV, Hepatitis B, and MMRV too. But, Arizona leaders still have some local tools to protect some access.
By being prepared to act quickly after the September 18 and 19 ACIP meeting via AHCCCS, the Department of Insurance, and the ADHS… we might be able to mitigate some of Kennedy’s damage at least in the short run.
