HHS’s Stance on Vaccine Shared Decision-Making Risks Patient Health and Overloads Clinicians

Health and Human Services (HHS) Secretary Robert F. Kennedy Jr. wants Americans to engage in “shared decision-making” with their health care providers to decide which vaccines, if any, they want for themselves or their children.  

In an already stressed primary care system, that’s a tall order.   

“Primary care already has limited time with patients because of the continued underinvestment in primary care. And so, this is an added request,” said Ann Greiner, president and chief executive officer of the Primary Care Collaborative, which advocates for a more robust US primary care system. 

An Equivocal Message 

With vaccine hesitancy on the rise, public health experts say support for a shared decision-making approach, rather than a clear-cut endorsement based on years of science, sends a dangerously equivocal message about the value of immunization. But shared decision-making is a big part of the pared-back childhood vaccine schedule released by HHS on January 5.  

It’s not that health experts, including those who disagree with many notions that Kennedy and his MAHA movement promote, are against doctor-patient conversations. To the contrary, conversations with trusted doctors, nurses and other providers can address patients’ concerns. 

Kelly Moore, MD, MPH, the former director of the Tennessee Immunization Program who is now CEO of Immunize.org, a nonprofit that has resources for both parents and providers, affirmed that patients and doctors do shared decision-making all the time. It is and should be an intrinsic part of medical care. 

“Everything that you and your health care provider decide to do is a matter of shared clinical decision-making,” she said. “Your health care provider cannot do things to you without your consent.”  

But in the context of vaccines, the phrase “shared decision-making” can get confusing. Used colloquially, “shared decision-making,” is just what it sounds like. Patient and provider going over the pros and cons and deciding on a course of treatment, a plan of care.  

But when the Centers for Disease Control and Prevention (CDC) formally recommends “Shared Clinical Decision Making,” it means that although a vaccine is Food and Drug Administration (FDA)-approved (meaning it’s safe and effective), the CDC isn’t saying that everybody of a certain age or risk group should get it. Instead, patients should discuss with their doctors whether they fall in the subset of people that would most benefit.

One example that predated Kennedy’s appointment to HHS was the HPV vaccine, which protects against a virus that can cause cervical or other cancers. For pre-teens, the CDC recommendations were clear: children aged nine and 10 “can” get it, and for 11 and 12 year olds it’s recommended. But for adults age 27 to 45, the CDC recommended “shared clinical decision-making,” depending on their intimate relationships and lifestyle. Many adults just don’t need it. 

Recently and controversially, the CDC formally stripped the Hepatitis B dose at birth from recommended to “shared clinical decision-making.” That’s also now the designation, too, for Covid boosters for all age groups, (with stronger recommendations for certain people at high risk). The Jan. 5 announcement from HHS added rotavirus, Covid-19, influenza, meningococcal disease, hepatitis A, and hepatitis B shots to the vaccines subject to “shared clinical decision-making.” 

It also recommended several shots for high-risk children or populations but not for all kids. Those include immunizations for respiratory syncytial virus (RSV), hepatitis A, hepatitis B, dengue, meningococcal ACWY, and meningococcal B. 

Limited Access to Care  

One challenge to keeping kids who have not received the previously recommended vaccines healthy is US patients’ limited access to primary care. About 3 out of 10 adults, and one in 10 kids, doesn’t have a regular primary care provider, according to the Milbank Memorial Fund and The Physician Foundation’s 2025 Primary Care Scorecard. Even for patients who do have a regular primary care clinician, it can be a hassle (and a wait) to get an appointment — and it may also require parents taking time off from work. Because the appointment may be limited to 12 to 15 minutes, it may take more than one visit to get through all the concerns around immunization, plus other health promotion topics and health conditions that may require attention. 

And for the 27 million uninsured — a number that’s expected to climb now that the Affordable Care Act enhanced premium subsidies have expired (and premiums are rising) — paying for “shared decision-making” doctor’s visits is one more financial burden for families and the health system.

Clinician Burden 

Plus, with large patient panels and documentation and administrative tasks spilling into nights and weekends, primary care doctors already have plenty to do, without significantly more vaccination decision-making transferred from the national public health system to their already heaping plates. 

But that’s already begun. 

Rebecca Etz, PhD, a cultural anthropologist and professor of family medicine at Virginia Commonwealth University, has found in her surveys run by the Larry A. Green Center that the current government messaging about preventive care and vaccination is already affecting primary care practice. Doctors are seeing more vaccine hesitancy, even among patients who did not earlier hold those views.  

Etz said roughly two-thirds of the physicians surveyed reported that their patients are “confused regarding vaccination guidelines and don’t know whose guidelines to follow.” Nearly half say that parents are expressing new hesitancy about childhood vaccinations. 

And while there isn’t a lot of strong survey data out there, it’s reasonable to at least wonder whether people who are the most firmly opposed to vaccines are going to even consult a doctor or nurse. KFF tracking surveys from the early Covid vaccination period showed that people who were most opposed to the vaccine were less likely to change their minds than people who were uncertain and wanted to “wait and see.” That’s a crucial finding for evolving work on combating misinformation and building trust, but it doesn’t say whether doctors tried and failed to persuade them — or whether they consulted medical professionals at all. 

A Shift Away from Science 

However, the MAHA-aligned Independent Medical Alliance (IMA) praised the recent change of course. 

“This is a long-overdue recalibration of the number of vaccines administered to newborns and young children at the very outset of life,”  IMA president Joseph Varone, MD, said in a statement. “HHS took a definitive step toward restoring balance, showing a strong willingness to continue questioning status-quo medical assumptions, and instead place the long-term well-being of children ahead of institutional pressures. We believe this marks the beginning of what will be the most consequential year of healthcare reform in modern American history.” 

For Moore, who also served on the CDC’s Advisory Committee on Immunization and Practices for years, “shared decision-making” is “a term of art. And that’s the problem.”

The shifting framework now implies, she said, “that the people who provide their health care are not telling them things, not informing them adequately unless there’s a shared clinical decision-making recommendation. And that couldn’t be further from the truth.” 

There are other potential ramifications. Many states tie their childhood immunization requirements, for both schools and childcare, to ACIP recommendations. Insurance coverage is also linked to the federal regulatory decisions — though so far, the payers are still covering the shots, and HHS said that government programs like Medicaid and Affordable Care Act plans would continue to do so. 

Moore and others worry that the shifting decision-making processes could affect coverage – and beyond. “If the ACIP downgrades a recommendation to shared clinical decision-making, that calls into question whether it should be required for childcare or school entry,” she said. “That may mean that that requirement goes away in a state.” 

Or if requirements remain, but are no longer linked to clearcut ACIP/CDC recommendations, they may prove newly vulnerable to legal challenges. It’s easy to envision anti-vax or vaccine skeptical organizations or advocates saying, “If the ACIP doesn’t think all children should get this shot, how can you require it?” 

“I think this is a strategy,” Moore said, adding that their goal is to “unravel” state requirements for childcare and schools. 

And that, many pediatricians and public health experts fear, will lead to more confusion. Less immunization. And ultimately, more preventable disease.