Kennedy presented the President with another Executive Order this week aimed at watering down the childhood vaccine schedule. You might have read some stories about how a big of a deal it is… but it’s not the threat some think it is.
The real threat is Kennedy’s ongoing effort to pack the Advisory Committee for Immunization Practices with his anti-vaccine friends. More on that in a bit.
See the EO
The order says doctors and families should follow Kennedy’s recommendations rather than the ACIP and CDC recommendations (the ACIP/CDC recommendations are what congress has established as driving immunization policy and practice).
He thinks influenza, COVID-19, rotavirus, hepatitis A & B and meningococcal vaccines should be in narrower recommendation categories. He also thinks the MMR should be separated into separate vaccines – which would result in a lot more doctor visits. But it won’t happen. I’ll explain later.
Importantly, this week’s EO doesn’t do anything to change actual vaccine access and insurance coverage. It doesn’t change evidence based medical practice. It doesn’t change vaccine antigens in vaccines, and it doesn’t even change state school vaccine requirements.
ACIP Is Still the Policy Lynchpin
The reason is something I’ve written about a bunch over the last year: the CDC’s Advisory Committee on Immunization Practices (ACIP) is what really drives vaccine coverage.
Federal law requires most commercial health plans to cover ACIP-recommended vaccines without a co-pay or deductible
ACIP recommendations also drive the Vaccines for Children Program (VFC), which provides vaccines for Medicaid eligible and enrolled kids, uninsured kids, American Indian and Alaska Native children and some underinsured kids.
This Executive Order doesn’t change the existing ACIP recommendations or the VFC coverage that goes with them.
I also seriously doubt pediatricians are suddenly going to rearrange their practices around a White House Executive Order (even doctors who voted for Trump). The vast majority of clinicians will continue to use evidence-based practice to drive their clinical decisions and recommendations – sources like American Academy of Pediatrics and the AMA.
The Real Threat Down the Road
Even though the EO this week isn’t going to undermine vaccination coverage (at least from a policy perspective) Kennedy is still trying to dramatically water down our current evidence-based vaccine. His strategy is to stack the ACIP with his anti-vax friends who could then dramatically undermine the vaccine schedule and insurance coverage.
How?
First, Kennedy fired all 17 sitting ACIP members (June 2025) and replaced them with his own appointees, many of whom are well-known anti vaxxers. The plaintiffs (including APHA) argued in court that the reconstituted committee violated the Federal ACIP Act and the Administrative Procedure Act, including requirements concerning balance and the process used to constitute the committee.
Judge Brian Murphy agreed that the plaintiffs were likely to prevail and stayed the appointments of 13 replacement members that were before him, along with all votes taken by that ACIP.
After that, Kennedy tried to go around ACIP in January 2026. Then Acting CDC Director Jim O’Neill issued a new childhood schedule that reduced the number of routinely recommended vaccines from 17 to 11 and narrowed several others. ACIP did not participate in that decision.
Judge Murphy separately concluded that Congress had required ACIP’s involvement in the CDC immunization schedule and that O’Neill lacked authority to make those changes without it. He therefore stayed that January schedule too.
Those decisions are now on appeal at the U.S. Court of Appeals for the First Circuit.
The First Circuit isn’t a great place from Kennedy’s point of view. Five of its six judges were appointed by Democratic presidents. That doesn’t tell us how the panel will rule, but it’s a lot better than being in the 5th Circuit for example.
Note: When plaintiffs sue Democratic presidents they usually file in the 5th Circuit (Texas) because they know they’ll likely get right of center judges. When plaintiffs sue Republican presidents they never file in the 5th circuit – usually the 1st (New England) or 9th (a bunch of western states including California).
Even if Kennedy wins at the First Circuit, it won’t automatically bring his January 2026 vaccine schedule back to life. He’d get his stacked ACIP back and then use it to make the vaccine policy changes he wants.
Kennedy only has until January 2029 to get his agenda through the administrative process and make it stick. In federal litigation time, that’s not a long time. Every month his ACIP is defunct is another month he can’t use it to dismantle evidence-based vaccine recommendations and insurance and VFC coverage.
And Then There Are School Vaccine Requirements
There’s another part of the EO you might have read about. The part that encourages states to water down or end their school vaccine requirements. The Order “advises” states and territories to review their laws and regulations and consider changing which vaccines are required for school enrollment.
School vaccine requirements are state policy, not something the President gets to rewrite with an EO. That doesn’t make this part harmless. If red states take the EO seriously we could end up with another patchwork where childhood vaccine protections depend increasingly on what state you happen to live in.
Note: In Arizona the school vaccine requirements could be watered down in two different ways. A Governor Biggs could simply tell his ADHS director to water down or drop several of the school required vaccines in Rule (9 A.A.C. 6). That would take about 18 months to 2 years.
Alternatively, the legislature could pass a bill to preempt the ADHS school vaccine requirements by watering down or eliminating them – and then a Governor Biggs would need to sign that). That could take effect in the fall of 2027 if that happened.
Three Separate MMR Shots? Good Luck With That
The EO also says measles, mumps and rubella vaccines should be given as three separate shots instead of the combined MMR vaccine. It’s a dumb idea of course for lots of reasons… but there’s a huge practical problem for Kennedy: separate measles, mumps and rubella vaccines aren’t licensed in the U.S. anymore.
For this idea to go anywhere, a manufacturer would have to develop three separate products, do the trials needed for FDA approval, manufacture them and build a market for them. And why would they? We already have safe, effective MMR vaccines that do the same job with one shot instead of three. A company would be spending a bunch of money developing products mainly so kids could get three injections instead of one and then lose money in the end… plus have the risk that the next administration would undo it! They wouldn’t even be done with the trials by then! Not gonna happen.
Conclusion
So, for now anyway, this Executive Order looks like it’s grasping at straws. But it’s not harmless either.
Every time the President & Kennedy tell parents that childhood vaccines aren’t really necessary (or even harmful), they create more doubt. Some will delay. Some will skip doses. Some who were already on the fence will decide not to vaccinate at all.
That lowers vaccination rates even if insurance coverage and clinical practice doesn’t change.
The big threat is Kennedy’s effort to gain control of ACIP and use it to change the recommendations that actually drive vaccine policy, VFC and insurance coverage. If he succeeds, the consequences will most definitely be much bigger than anything in this week’s Executive Order.
But they have a problem: the courts and the clock. And maybe even Congress, after the midterm election.