Section 32.1-46 of the Code of Virginia requires that the Board of Health conduct an annual review of statutory childhood immunization requirements. Further, the law requires that the Board of Health make recommendations for revision to the Governor, General Assembly, and Joint Commission on Health Care by September 1st of each year.

The Virginia Department of Health conducted an analysis of Virginia’s immunizations required for school entry compared to 1) recommendations from the Centers for Disease Control and Prevention (CDC), the Advisory Committee on Immunization Practices (ACIP), the American Academy of Pediatrics (AAP), and the American Academy of Family Physicians (AAFP), and 2) CDC Recommended Child and Adolescent Immunization Schedule. The findings are listed below.

FINDINGS

1. In 2008, ACIP originally recommended influenza immunization for school-age children. There has never been an influenza immunization requirement for school entry in Virginia; however, CDC/ACIP/AAP/AAFP all recommend an annual influenza vaccine for all children six (6) months of age and older and they recommend that children age six (6) months to eight (8) years who have not received two (2) doses of annual influenza vaccine before July 1, 2024 or whose vaccination history is unknown should receive two (2) doses separated by four (4) weeks. The CDC Recommended Child and Adolescent Immunization Schedule is consistent with those recommendations.

2. In 2022, ACIP initially recommended COVID-19 immunization for school-age children. At the time, this recommendation was shared by the CDC, AAP, and AAFP. In 2025, following a request from Secretary Kennedy, the CDC revised its guidance for COVID-19 immunization from routine to shared clinician decision-making. At the time of this report, the newly established ACIP committee has not yet voted on COVID-19 vaccine recommendations and AAP maintains its COVID-19 immunization routine recommendation. There has never been a COVID-19 immunization requirement for school entry in Virginia; however, ACIP recommendations established by the prior committee and AAP recommend 1 to 3 doses depending on age and vaccine manufacturer with at least one dose being an updated COVID-19 vaccine for that season (i.e. at least one 2024-2025 Formula). The CDC Recommended Child and Adolescent Immunization Schedule is inconsistent with those recommendations and ACIP has not yet voted on a 2025 recommendation.

3. In 2023, ACIP recommended Respiratory Syncytial Virus (RSV) immunization for all infants 0 – 8 months old who were born during or are entering their first RSV season if the mother did not receive an RSV vaccine during pregnancy, mother’s RSV vaccination status is unknown, or the infant was born within 14 days of maternal RSV vaccination. There has never been an RSV immunization requirement for school entry in Virginia; however, CDC/ACIP/AAP/AAFP all recommend 1 dose for each infant’s first RSV season with consideration of mother’s vaccination status. The CDC Recommended Child and Adolescent Immunization Schedule is consistent with those recommendations.

4. Incorporation of influenza, COVID-19, and RSV vaccines into Virginia’s childhood immunization statute would present substantial fiscal and logistical challenges.

5. In order to align Virginia’s requirements with the recommendations of these organizations, the Board of Health would need to amend the Regulations for Immunization of School Children to add three new immunization requirements.

6. The Virginia Board of Health does not recommend revisions to § 32.1-46 of the Code of Virginia or the Regulations for the Immunization of School Children at this time.

7. The Virginia Board of Health raises concern that the AAP does not currently endorse the recent changes made to the CDC Recommended Child and Adolescent Immunization Schedule. The recent changes and management of ACIP have also increased concern among public health and healthcare provider industry groups. The Virginia Board of Health will continue to monitor developments regarding the reconstitution of ACIP and work to ensure that Virginians have access to safe, effective vaccines based on the best available scientific evidence.