Public engagement and input are vital to the vaccine regulatory process in the United States. Each time the Advisory Committee for Immunization Practices (the committee of independent experts who advise CDC recommendations) meets, CDC accepts public comment. Members of the public are invited to submit comments to ACIP in the form of written comments submitted via regulations.gov, and/or by requesting to make an oral public comment at ACIP meetings.
Vaccinate Your Family routinely submits written comments and requests oral comments as part of our advocacy for evidence-based vaccine recommendations that protect as many people as possible from vaccine-preventable diseases. We also encourage other advocates and community members to submit your own comments and use your voice in this process. Learn more about submitting ACIP comments here.
Vaccinate Your Family submits this comment to reaffirm the importance of the vaccines recommended by the ACIP in safeguarding our nation’s health and to call on the Administration to uphold the integrity of vaccine regulatory pathways and safety systems.
Vaccinate Your Family (formerly named Every Child By Two) was formed on the heels of the measles epidemic of 1989-90 which grew to over 50,000 cases. Our co-founders, former First Lady Rosalynn Carter and Betty Bumpers knew that the 150 lives lost to a vaccine-preventable disease were too many and so they dedicated their lives to vaccine advocacy. VYF has been a nonpartisan voice for 35 years, working with the White House and Congress to protect all of our communities. The United States finds itself at another critical moment – children are once again dying from measles, a vaccine-preventable disease.
From the very top of the government response, efforts must be focused on saving lives with the best tools we have – vaccines. Instead, our organization fears that the HHS Secretary’s slow response to the outbreak and dismantling of HHS now takes the shape of an ideological pursuit to undermine our nation’s immunization programs. This is evidenced through the defunding of public health, mass firings of experts, disruption of regulatory pathways, and the hiring of discredited researchers to manipulate safety data to prove discredited theories. All of this is resulting in the erosion of public confidence in our nation’s stellar vaccine safety systems, contributing to the deaths of children from diseases these vaccines can prevent.
Vaccinate Your Family is pleased this ACIP meeting is happening. Health officials including the HHS Secretary are calling for increased transparency; holding public meetings like this convening of the ACIP and the regularly scheduled VRBPAC meetings at the FDA is how we keep our nation’s vaccine approval, recommendation and ongoing safety review process transparent. Unfortunately, VRBPAC meetings have been cancelled without any information on scheduling for 2025. The federal process of reviewing vaccine safety and efficacy data and making recommendations is already less transparent than it was this time last year.
In support of transparency and keeping conflicts of interest out of our vaccine recommendations, it’s important to note that ACIP members are and have been subject to robust disclosure policies. Members make annual financial disclosures, are required to divest from vaccine manufacturer stock, and there is a prohibition on accepting industry payments. We have personally witnessed members recusing themselves from any vote in which they may be conflicted. Occasionally, ACIP members do disclose conflicts when they’ve worked on a study, held a patent, or are otherwise involved in the creation of or monitoring of a specific vaccine. The expertise of these individuals is essential, as we need the people who understand vaccines best to serve on the ACIP.
As of the writing of this comment, two children have died in Texas from measles – the first pediatric measles deaths in our nation in over two decades. Parents choosing not to vaccinate want to keep their families safe, as we all do. They believe they are making a safer choice by choosing not to vaccinate – but unfortunately this is not what the data show, and fear is costing lives. It is true that vaccines, like all medical interventions, come with the risk of rare side effects, but outsized fears are being allowed to grow rather than being right-sized by those in leadership. This is costing lives today.
At ACIP, experts sit down with the best available data to examine the risks of not vaccinating vs. the risks of vaccinating and ONLY recommend a vaccine when the benefits outweigh the risks. Again, we have witnessed this process for three decades and trust in the decisions rendered by this body. We’ve heard from the new administration that they support “informed consent” in vaccination – an informed choice to vaccinate is made when someone understands the benefit of a vaccine as well as the potential risks (and how small they truly are as compared to the risk associated with their child contracting measles, for example). ACIP meetings reviewing robust safety and efficacy data make informed consent possible.
When vaccines work (as well as the safety systems, regulatory meetings, and delivery systems that support them), nothing happens. People are protected and their families remain safe from deadly preventable diseases. Vaccines are a victim of their own success. The ongoing measles outbreak, as well as whooping cough and flu deaths, are stark reminders that our nation’s public health is hard fought and fragile. We thank the ACIP members for their ongoing work to make sure vaccines remain safe, effective, and recommended appropriately.