(WASHINGTON, D.C.)—The Governors Public Health Alliance (PHA), a nonpartisan coalition of 15 Governors representing approximately one-third of the U.S. population, submitted comments to the U.S. Department of Health and Human Services (HHS) in response to its request for information on categories used in federal vaccine recommendations and the role of shared clinical decision-making.
In its comments, the Alliance stated: “Changes that introduce uncertainty, increase administrative complexity, or reduce public confidence may have far-reaching effects on State implementation, public health operations, and the ability of Governors to protect their communities from vaccine-preventable disease. PHA therefore urges HHS to preserve a stable national vaccine recommendation framework, maintain transparent and evidence-based advisory processes, avoid changes that create unnecessary implementation burdens, and fully assess and publish the operational, fiscal, and public health impacts on states before acting, and to proceed by notice-and-comment rulemaking for any change carrying legal effect.”
“Governors have a responsibility to protect the health of their communities, and they need clear, credible, and evidence-based federal guidance to do that effectively,” said Angela Botticella, Managing Director of the Governors Public Health Alliance. “Federal vaccine recommendations have been integrated into state policies ranging from insurance coverage requirements to provider scope of practices rules to emergency public health protocols. And it’s Governors and their residents who bear the brunt of any increased disease outbreaks due to confusion related to hastily made federal changes.”
Federal vaccine recommendations have been deeply integrated into state public health systems. PHA’s comments warn that changing recommendation categories could force states to reassess policies, update guidance and provider communications, coordinate with insurers and health systems, and modify immunization systems—placing additional demands on already constrained state public health resources.
Governors also bear the human, operational, and financial consequences when vaccination rates decline and outbreaks occur. PHA notes that a single 2025 measles outbreak spanning Texas and New Mexico resulted in several deaths and cost nearly $5.4 million to contain across 100 confirmed cases.
PHA’s full comments are available HERE.
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About the Governors Public Health Alliance
The Governors Public Health Alliance (PHA) is a nonpartisan coalition of Governors—representing nearly one in three people in the U.S.—working together to strengthen public health systems, protect access to evidence-based care, and coordinate responses to health threats across state lines. An initiative of GovAct, the Alliance brings together Governors and senior state officials to share best practices, reinforce scientific integrity, and ensure communities receive clear, credible health information. To learn more, go to www.govsforhealth.org.
About GovAct
Governors Action Alliance (GovAct) is a nonprofit nonpartisan initiative that unites Governors in working across state lines to champion fundamental freedoms and improve people’s lives. GovAct serves as a central platform for collaboration across Governors’ offices—incubating, launching, and supporting alliances of Governors. These alliances share cutting-edge policy and legal approaches to some of the most challenging and critical issues we face. To learn more, go to www.GovActAlliance.org.