Sept. 13, 2025
Martin Kulldorff, PhD
Chair, Advisory Committee on Immunization Practices
Centers for Disease Control and Prevention
1600 Clifton Road NE
Atlanta, GA 30333
RE: Comments for the September 2025 meeting of ACIP (Docket No. CDC-2025-0454)
Dr. Kulldorff:
On behalf of the 30,000 members of the American Thoracic Society we appreciate the opportunity to submit comments on the items before the CDC Advisory Committee on Immunization Practices for the September 2025 meeting.
Founded in 1905, the American Thoracic Society is the world's leading medical society dedicated to accelerating the advancement of global respiratory health through multidisciplinary collaboration, education, and advocacy. Core activities of the Society’s more than 30,000 members are focused on leading scientific discoveries, advancing professional development, impacting global health, and transforming patient care. Key areas of member focus include developing clinical practice guidelines, hosting the annual International Conference, publishing four peer-reviewed journals, advocating for improved respiratory health globally, and developing an array of patient education and career development resources. As a society representing clinicians treating patients with serious respiratory conditions, patient access to vaccine and community adoption of vaccine is of upmost importance to the patients we care for. It is with our clinical expertise and concern for our patients that we offer the following comments.
Retain the February 2025 ACIP Child and Adolescent Routine Vaccine Schedule
The ATS strongly urges ACIP to retain the child and adolescent routine vaccine recommendations of February 2025, aligned with the recent American Academy of Pediatrics routine vaccine schedule. ATS members treat many young patients with pulmonary conditions - including asthma, cystic fibrosis, chronic bronchitis, bronchiolitis, interstitial lung disease, sleep disordered breathing, and bronchopulmonary dysplasia – who are uniquely vulnerable to preventable infectious diseases. For many of our pediatric patients, what might be a mild infection in other kids is a potentially life-threatening infection for children with respiratory disease. For these patients, access to routine vaccination is essential to their life and health. While individual patient access to vaccine is essential, protection is further enhanced by community wide adoption of vaccination against preventable infectious diseases. Our pediatric patients’ health and wellbeing depend not only on individual access to vaccines but broad community adoption. In addition, the protection of our adult patients with chronic lung disease is aided by their community and family being vaccinated.
Retain the February 2025 ACIP COVID-19 vaccine schedule as the American Academy of Pediatrics (AAP) and American College of Obstetricians and Gynecologists (ACOG) recently recommended to their society members.
The ATS urges ACIP to strongly consider the COVID-19 vaccine recommendations issued by the AAP and ACOG. We note those recommendations did not restrict vaccination to only those with chronic underlying conditions. The evidence is undeniable: COVID-19 vaccination saves lives by preventing severe infections and reducing the risk of death. As pulmonary and critical care physicians, we have witnessed firsthand the devastating toll of acute and long COVID on pregnant and healthy individuals of all ages as well as those with underlying health conditions. Vaccination remains one of the most powerful tools we have to protect our communities.
Ensure family members and close contacts of individuals with high-risk conditions have access to COVID-19 vaccines.
We note with concern that COVID-19 vaccination recommendations made by ACIP after February 2025 now exclude healthy individuals younger than 65 years. Thus, the vaccine is not broadly available to all community members, for example household members and persons with occupational contact with individuals with high-risk conditions. COVID-19 vaccines should be available and covered by insurance for all persons who want to protect themselves and their contacts. Without ACIP recommendations for COVID-19 vaccination of groups, we fear that insurance coverage could jeopardize these protective vaccines. This will disproportionately affect Medicaid patients who already face significant financial and access barriers.
ACIP COVID-19 vaccine recommendations since February 2025 have been restrictive and have added barriers to vaccine access.
ACIP recommendations are relied upon by public and private health insurers and impact reimbursement policies for vaccines. Recent changes in COVID-19 policy have created confusion with health insurers, pharmacies, and physician offices. This administrative confusion is another barrier to patients receiving safe and effective COVID-19 vaccines. Requiring family members and close contacts to get a physician prescription for the COVID-19 vaccine is a needless barrier to a safe and effective vaccine and will place pointless administrative demands on physicians and their staff to process the COVID-19 prescription requests.
The ATS appreciates the opportunity to submit these comments. We look forward to the forthcoming ACIP meeting discussion and hope it will be guided by the preponderance of available scientific data and by the input of the physician community.
Sincerely,
Raed A. Dweik, MD, MBA
President
American Thoracic Society