In December, the Centers for Medicare and Medicaid Services announced an end to state vaccine reporting requirements, effectively reversing a 2024 mandate.
The change applies to children and adults enrolled in Medicaid or the Children’s Health Insurance Program (CHIP), programs that combined cover nearly 40 percent of children under age six in the United States.
State reporting on a variety of metrics, including behavioral health care, preventive care, chronic conditions, dental care, and immunizations, was voluntary for children enrolled in the programs until a 2024 mandate went into effect. Annual data on the behavioral health of adult beneficiaries became mandatory the same year.
Government regulators use the Child Core Set and Adult Core Set reporting requirements to improve health care quality and access for patients enrolled in Medicaid and CHIP, according to the Centers for Medicare and Medicaid Services (CMS). The children’s core set was established in 2009, while measures to collect data on Medicaid-enrolled adults were passed under the Affordable Care Act.
Funding at Stake
States that fail to report annually on CMS “Core Set” data could lose out on massive federal funding.
That would have included reporting on the vaccination status of Medicaid and CHIP beneficiaries,’ but Health and Human Services (HHS) Secretary Robert Kennedy has now removed multiple immunization requirements.
The four Core Set measures removed, effective 2026, are Childhood Immunization Status, Immunizations for Adolescents, Prenatal Immunization Status of women under age 21, and Prenatal Immunization Status of women over age 21.
States “may voluntarily report on the results,” but are no longer mandated. Furthermore, CMS “strongly discourages” states from attaching monetary incentives to vaccination.
Vaccine Overhaul
Since his appointment in 2025, Kennedy has overseen significant changes to vaccine policy.
In June, Kennedy reversed the recommendation that healthy children and pregnant women receive COVID-19 shots. Kennedy replaced all 17 Biden-appointed members of the Advisory Committee on Immunization Practices (ACIP).
In August, Kennedy announced the reinstatement of the Child Vaccine Task Force after a nearly 30-year hiatus and dismissed Centers for Disease Control and Prevention (CDC) director Susan Monarez. Several CDC senior officials quit in protest.
ACIP member Robert Malone said the shake-up was due to the agency’s unwillingness to recognize vaccine injuries. More recently, the Trump administration issued a memo to HHS announcing a major revision of recommended vaccines for pediatrics, to align with “best practices from Peer, and Developed Countries.”
Freedom and Consent
The CMS removal of reporting mandates is another step Kennedy has overseen, a move intended to protect informed consent and patient freedom. “Government bureaucracies should never coerce doctors or families into accepting vaccines or penalize physicians for respecting patient choice,” wrote Kennedy on X .
“The decision by CMS to drop vaccination reporting requirements restores a degree of clinical autonomy to physicians,” said Michelle Cretella, M.D., past executive director of the American College of Pediatricians (ACPeds).
“While the left-wing AAP (American Academy of Pediatrics) and health departments in several Democrat-run states continue to promote the old vaccine schedule, the removal of federal funding ties reduces the systemic pressure on doctors. Over time, this shift will allow for more personalized medical decision-making without the burden of federal mandates.”
The mandates do influence what goes on in the exam room, says Peter McCullough, M.D., the president of the McCullough Foundation.
“If insurance companies and health systems follow the CMS change, then yes, physicians will be under less pressure to push childhood vaccines on concerned parents with infants and toddlers,” said McCullough. “Because like any drug, parents should participate in shared vaccine decision making with the doctor; there should be no outside pressure, coercion, or threat of reprisal regarding the decision.”
Patient Privacy
Although vaccinations should always be reported in a patient’s record, there is no reason CMS would need that information other than to tie payment to it, says Jane Orient, M.D., the executive director of the Association of American Physicians and Surgeons.
“This is an illegitimate use of government power to coerce behavior and corrupt the patient-physician relationship,” said Orient.
Vaccine Data, Not Off the Shelf
While no longer required, CMS acknowledges a need for data on vaccine practices.
“In 2026 and beyond, CMS will explore options to facilitate the development of new vaccine measures that capture information about whether parents and families were informed about vaccine choices, vaccine safety and side effects, and alternative vaccine schedules,” said Dan Brillman, CMS deputy administrator, in the letter announcing the update.
“CMS plans to engage with stakeholders…to learn how new measures could capture person and family preferences related to vaccines,” wrote Brillman. “CMS will also explore how religious exemptions for vaccinations can be accounted for in the data and the subsequent measures.”
The reporting changes will paint a clear picture of what drove vaccination decisions in the past, says Allison Lucas, policy director at Citizens Council for Health Freedom.
“Physicians continue to have the freedom to recommend and administer vaccines,” said Lucas. “In the long run, it will be interesting to see whether physician vaccine ideology changes as the ‘settled science’ on vaccines is scrutinized by health agencies, if outside financial incentives for vaccination are eliminated, or if vaccine administrators and manufacturers are again held liable for vaccine injury.”
Ashley Bateman ([email protected]) writes from Virginia.
