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Attorney General Nessel Calls on Trump Administration to Stop Undermining Federal Vaccine Guidance

LANSING — Michigan Attorney General Dana Nessel has joined a coalition of 22 attorneys general and the Governor of the Commonwealth of Pennsylvania in urging U.S. Department of Health and Human Services (HHS) Secretary Robert F. Kennedy, Jr. to keep federal vaccine recommendations grounded in science and medical evidence (PDF). In a letter responding to HHS’s request for information on vaccine recommendations and shared clinical decision-making, the coalition warns that HHS’s actions over the past year — including efforts to weaken the childhood vaccine schedule and sideline the experts responsible for developing federal vaccine recommendations — have created confusion and have made it harder for states to rely on federal public health guidance. The letter urges HHS to halt additional changes that could lower vaccination rates and leave more people vulnerable to preventable diseases.

“Public health experts have guided our nation’s vaccine recommendations for decades,” said Attorney General Nessel. “Their institutional knowledge is critical to providing families with sound information. Replacing the current guidance with policies that create more confusion and uncertainty puts the health of Michiganders at risk. I am committed to working with other states to protect public health and ensure families have access to clear, evidence-based health information.”

In the letter, Attorney General Nessel and the coalition urge HHS to:  

  • Examine its own role in undermining public trust through its recent changes to vaccine policy. HHS has not identified a change in the scientific evidence on vaccine safety or effectiveness that would justify overhauling the current recommendation categories. Instead, the coalition points out that recent federal actions have contributed to the very public distrust HHS says it wants to address.
  • Preserve the role of the Advisory Committee on Immunization Practices (ACIP) in setting vaccine recommendations. ACIP is a 17-member federal advisory body whose science-based recommendations form the bedrock of federal vaccine policy, as Congress intended, and serve as a cornerstone of state health codes. In June 2025, Secretary Kennedy dismissed all 17 ACIP members and quickly reassembled it with new members who did not undergo the typical vetting process. The coalition warns that replacing ACIP with the Task Force for Safer Childhood Vaccines, which HHS reinstated in August 2025 after nearly three decades of dormancy, would undermine ACIP’s critical role. The 2025 reassembly of ACIP is also the subject of ongoing litigation.
  • Retain the current vaccine recommendation categories. Under the current three-tiered recommendation structure for vaccines — routine, risk-based, and Shared Clinical Decision-Making (SCDM) — most vaccines are routinely recommended, while SCDM allows providers and patients or caregivers to weigh a vaccine’s benefits and risks based on individual circumstances. These categories have historically provided clear, efficient, and evidence-based guidance for states’ public health and Medicaid programs. The coalition notes that the request for information specifically asks about SCDM after HHS recently moved to expand its use, including for the hepatitis B vaccine birth dose, without identifying new scientific evidence to support the changes. SCDM is appropriate only in limited circumstances, and its misuse threatens public health.

The letter comes as Attorney General Nessel continues to challenge the Trump administration’s changes to federal vaccine policy. In February 2026, Attorney General Nessel joined a multistate lawsuit challenging the administration’s overhaul of the childhood immunization schedule. This month, a federal judge ruled that the coalition has standing to challenge (PDF) the CDC’s changes to the childhood immunization schedule.

Joining Attorney General Nessel in the letter are the attorneys general of Arizona, California, Colorado, the Commonwealth of Virginia, Connecticut, Delaware, Hawaiʻi, Illinois, Maine, Maryland, Massachusetts, Minnesota, Nevada, New Jersey, New Mexico, New York, Oregon, Rhode Island, Vermont, Washington, and Wisconsin, as well as the Governor of the Commonwealth of Pennsylvania.

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