Flu Shot Co-Pays Rise Amid ACIP Limbo

Health insurance costs for new vaccines are rising as the Advisory Committee on Immunization Practices remains without a functioning quorum. Ron Kroening, a 63-year-old retired public health employee in Oklahoma, paid a $40 co-pay for the Moderna mRNA flu vaccine in October. His insurer, a member of the Association of Health Insurance Plans, told him the shot is not covered because it lacks a formal recommendation from the committee.

The current status stems from a series of administrative actions by HHS Secretary Robert F. Kennedy Jr. Kennedy cut childhood immunization recommendations by one-third and replaced ACIP members with handpicked allies. A federal judge halted these changes in September 2025, ruling the process was flawed. However, Kennedy has not nominated new members to replace the disbanded panel. This pause means no new vaccine recommendations are being issued, even as the FDA approves new products.

Under current law, insurers must cover new vaccines within one year of an ACIP recommendation. If the committee issues a recommendation in December 2026, coverage is required by January 2028. If the recommendation slips to January 2027, the deadline extends to January 2029. Lindsay Wiley, a health law professor at UCLA, noted that the legal requirement moves slowly, and the current delay pushes full coverage further into the future. The only exception is for Covid vaccines, which Congress mandated be covered within 15 days of a recommendation.

The uncertainty affects more than just flu shots. Some states block pharmacists from administering vaccines without an ACIP endorsement. Insurers are also experiencing delays in covering new RSV shots for seniors, despite prior committee approvals. Aaron Siri, a lawyer who previously represented Kennedy, stated that the Department of Justice and the White House are not making a serious attempt to revive the committee. Dorit Reiss, a vaccines expert at UC Law San Francisco, agreed, noting that the government is choosing not to install a new ACIP.

Kroening’s case illustrates the financial impact on consumers. While insurers can choose to cover vaccines before the legal deadline, many are waiting. The Moderna flu vaccine was approved by the FDA in August for adults over 50. Kroening said he still chose the new shot, but the co-pay created a barrier for those with lower incomes. He noted that his pharmacist did not mention other flu shot options that might have been fully covered.

The government has appealed the portion of the court order that disbanded the committee. However, experts say there is nothing stopping Kennedy from following the correct appointment process. He has not done so. Reiss said that without dramatic statutory changes to protect the committee’s independence, it may not return to its previous form. The current pause allows the administration to bypass the committee’s slower decision-making process while it seeks to implement its own policy preferences.

Kroening said he is able to afford the $40 co-pay but remains concerned about the state of immunization access. He described the current environment as a mess, noting that vaccines are harder to obtain now. The AHIP industry group has vowed to continue covering all shots recommended as of September 2025, but new products approved after that date face an uncertain path to full insurance coverage.