When the rules governing a federal advisory committee are rewritten, the change shapes who serves on it and how its recommendations carry weight.
The CDC’s vaccine panel is the latest example.
In a recent article by Bloomberg Law, the publication examined the CDC’s revised charter for the Advisory Committee on Immunization Practices, posted as Secretary Robert F. Kennedy Jr. seeks a path forward after a court halted his overhaul of the panel. Richard H. Hughes IV, a Member of the Firm in Epstein Becker Green’s Health Care & Life Sciences practice and counsel for the plaintiffs challenging those changes, assessed the new document.
The charter routes management of the committee through the CDC director’s office rather than the agency’s immunization center, giving political leadership more involvement. It broadens the criteria for appointing members, lets the committee meet at a federal officer’s discretion rather than on a set schedule, and places greater weight on scrutinizing vaccine safety data and non-vaccine alternatives. It also reshapes the panel’s non-voting liaison groups, dropping one professional association and adding organizations that have questioned vaccine safety.
“Taken together, these changes suggest HHS is reshaping ACIP’s structure, membership environment, and operating framework while reducing the charter’s explicit acknowledgment of the legal consequences that make ACIP so important.”
Get in Touch
To discuss this perspective, contact Richard H. Hughes IV at RHHughes@ebglaw.com.
