Will Vaccines Become Unavailable Under RFK Jr.?

Early analysis of potential impacts on vaccine access under new HHS leadership

Since the announcement of RFK Jr.'s appointment as Secretary of HHS, our inbox has been flooded with messages from concerned parents and healthcare professionals about potential impacts on vaccine access. As we work to understand and analyze the situation, I want to share my current understanding and high-level assessment - while acknowledging that much remains speculative at this stage.

Let's break this down from a legal and policy perspective, focusing on the most immediate and concrete areas of potential impact… with the disclaimer that I am neither an expert in law nor policy!

Others have discussed potential impacts on vaccine access- including two fantastic reads by Skeptical Raptor (here and here).

The way I see it, the most immediate concerns center around three key areas:

1. First, personnel changes. The Secretary of HHS has broad authority to appoint inferior officers and reconstitute advisory committees with minimal oversight. This power to reshape key decision-making bodies could significantly impact vaccine policy across multiple agencies. For example, changes to the composition of committees like ACIP (Advisory Committee on Immunization Practices) could shift vaccine recommendations that directly affect insurance coverage and access. While Kennedy committed during confirmation hearings not to revise ACIP recommendations, such commitments are generally unenforceable, and committees can be reconstituted.

2. Second, information management. We may see removal or alteration of agency health information, increased scrutiny of scientific publications, and shifts in how vaccine data is presented to the public. We're already seeing early signs of this - Louisiana's Department of Health recently announced it would no longer promote mass vaccination, and there are reports of health agencies being directed to modify their public health messaging. These changes in how information is presented and distributed can significantly impact vaccine uptake and public health decision-making.

3. Third, funding mechanisms. Changes to grants, Medicaid/Medicare coverage, and federal program requirements could affect vaccine access without requiring formal regulatory action. This could manifest through new conditions attached to federal grants, shifts in what vaccines are covered under federal programs, or changes to the critical Vaccines for Children Program which currently provides free vaccines to all US children. While Congress maintains significant control over major funding decisions, administrative requirements and implementation details provide considerable room for policy shifts.

Additionally, Kennedy has explicitly stated his intention to redirect NIH research priorities, claiming he would tell NIH scientists to "give infectious diseases a break for about eight years" while redirecting half of the budget to "preventative, alternative, and holistic approaches." While Congress ultimately controls NIH funding allocation, such shifts in research priorities could significantly impact future vaccine development and public health preparedness.

Why COVID-19 Vaccines Might Be the First Target

I have a sneaking suspicion that COVID-19 vaccines are particularly vulnerable under the new administration. While outright removal of existing vaccines would face significant hurdles, several mechanisms could restrict access:

First, emergency use authorizations (EUAs) for COVID vaccines could be more easily overturned than full approvals. Additionally, HHS has significant latitude to:

• Add restrictive conditions to new or updated COVID vaccine approvals

• Alter advisory committee compositions to shift recommendations toward "risk-based" approaches that could limit coverage

• Modify funding mechanisms and federal program coverage that enable access

• Scrutinize and potentially obstruct next-generation COVID vaccine development

Recent publications, including a deeply flawed paper calling for the market removal of COVID-19 vaccines, illustrate a growing pattern of misinformation. I co-authored a critical analysis of this paper here detailing how methodological failures and misused data are being weaponized to create fear. Papers like this, despite their flaws, could be used to argue against vaccine safety and efficacy, potentially impacting availability.

The immediate impact may come through administrative changes rather than direct regulatory action. Changes to advisory committees, grant conditions, and Medicare/Medicaid coverage could significantly affect vaccine availability without requiring formal license revocations.

The Bigger Threat: Public Trust and Misinformation

Perhaps the most immediate and dangerous impact of RFK Jr.'s leadership is the erosion of public trust in vaccines. His appointment alone has already emboldened vaccine-hesitant individuals and fueled misinformation, as evidenced by reports of parents delaying routine childhood vaccines while they "wait for Kennedy's research." The very agencies traditionally relied upon for public health guidance are now under the direction of someone with a long history of opposing mainstream vaccine science.

Looking Ahead

I want to be clear: This analysis isn't intended to cause fear or panic. Any significant changes would likely face intense pushback from medical professionals, public health organizations, and legal advocates. States may also maintain their own vaccine programs and recommendations, potentially providing some buffer against federal changes.

That said, if you've been putting off routine vaccinations or boosters - whether it's Tdap, which needs a booster every 10 years, or other recommended vaccines - it might be prudent to get those scheduled sooner rather than later. While dramatic overnight changes are unlikely, the landscape of vaccine access could become more complicated in the coming years.

We will continue monitoring developments and providing updates as they unfold.

Stay curious,

Unbiased Science

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