September 19, 2026

Re: Request for Information: Categories Used in Federal Vaccine Recommendations and the Role of Shared Clinical Decision-Making Docket No. HHS-OS-2026-0332

To Whom It May Concern:

The Center for Individual Freedom (CFIF) appreciates the opportunity to comment on the above-referenced Request for Information (RFI).¹  Specifically, CFIF urges the United States Department of Health and Human Services (HHS) to leave the current federal vaccine recommendation categories in place, rather than restructure them through the avenues outlined in this RFI.  

Simply stated, HHS already maintains a framework that balances personal choice with the demonstrated benefits of vaccination, and no change to that framework is needed.  The current categories, focused on routine, risk-based and shared clinical decisionmaking, were designed to protect patients while ensuring that recommendations reflect the best available scientific evidence.  Each category considers where the evidence for a given vaccine is strong enough to support a universal recommendation, where it supports a more targeted, risk-based approach and when the decision is best left to the patient, parent and clinician.  Adding new or modified categories would unnecessarily complicate a framework that already provides sufficient flexibility, and could create confusion for patients and providers.  

Rather than expanding or restricting the existing categories, HHS should ensure that federal vaccine recommendations are grounded in sound scientific evidence.  When scientific evidence is limited, uncertain or evolving, HHS should clearly communicate that uncertainty to the public rather than hide it through overly broad recommendations or new recommendation categories.  

Moreover, if HHS is considering any changes to the recommendation categories, it must ensure that those changes do not affect coverage under the National Vaccine Injury Compensation Program (VICP).  VICP provides an important, established mechanism to ensure individuals who experience vaccine-related injuries are adequately compensated, rather than subjected to prolonged litigation.  Any changes should not unintentionally jeopardize a vaccine’s eligibility for VICP coverage or potentially create uncertainty for patients, providers and manufacturers.  

This is not only a public health objection, but also one with which voters express concerns.  Specifically, new nationwide polling that CFIF conducted of likely 2026 voters found that 70% oppose the recent executive order changing federal childhood vaccine recommendations.  Moreover, 77% support maintaining standard childhood vaccine requirements for public schools.  Similar concerns are evident at the state level, with Florida voters opposing a proposed rule that would eliminate certain school-age vaccination requirements by a margin of more than two-to-one.  That polling makes it clear that voters express significant concerns about changes that could limit vaccine access or roll back existing childhood vaccination policies.  

For these reasons, CFIF urges HHS to leave the current federal vaccine recommendation categories in place, rather than restructure a system that is already working as intended.  The existing framework already appropriately balances personal freedom with public health and safety by ensuring Americans have access to the protection vaccines provide while preserving room for individual judgment about how and when to use them.  Changing that status risks uncertainty without providing a clear benefit to patients, parents or clinicians.  

Thank you for your time and consideration on this important issue.  

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1. CFIF is a nonprofit organization established in 1998 with the mission of protecting individual liberties, rule of law, market innovation and consumer choice.