ACIP revises vaccine recommendations

The U.S. Advisory Committee on Immunization Practices (ACIP) recently revised its recommendations regarding the combined measles, mumps and rubella (MMR) and varicella vaccine, known as MMRV, for children under 4 years old as well as the COVID-19 vaccine for individuals ages 6 months and older. The recommendations took effect on October 6, 2025, following adoption by the director of the Centers for Disease Control and Prevention (CDC).

The Department of Health and Human Services (HHS) also issued a press release on the recent changes to ACIP’s vaccine recommendations. Under the Affordable Care Act, non-grandfathered group health plans must provide certain preventive care benefits without cost sharing, including immunizations recommended by ACIP for routine use in children, adolescents and adults.

COVID-19 vaccine

Group health plans must provide first-dollar coverage for the COVID-19 vaccine to individuals ages 6 months and older based on “individual decision-making.” This means getting a COVID-19 vaccine will be a personal choice individuals will make in consultation with their physicians, nurses and pharmacists.

MMRV vaccine

Group health plans:

• Must provide first-dollar coverage for the MMR vaccine and for the varicella vaccine starting at age 12–15 months
• Must provide first-dollar coverage for the combined MMRV vaccine for children ages 4 and older, if parents prefer this vaccine
• May stop covering the combined MMRV vaccine for children under age 4 with no cost sharing, although they are not required to do so

Going forward

• Employer plan sponsors should review the changes to ACIP’s vaccine recommendations.
• Non-grandfathered group health plans generally will be required to continue to provide the COVID-19 vaccine, the combined MMRV vaccine, the MMR vaccine and the varicella vaccine without cost sharing for the individuals referenced in the ACIP recommendations, but first-dollar coverage for the combined MMRV vaccine for children under age four will no longer be required after the end of the current plan year. Employer plan sponsors will need to determine whether they will require employees to pay a portion of the cost of the combined MMRV vaccine for children under age four starting with the 2026 plan year.