CHD Calls on CDC Vaccine Advisers to Clarify Medical Exemption Guidelines to Protect Vulnerable Kids

Children are being deprived of federally protected disability protections, and “some have been badly injured after they were forced to take vaccines against medical advice so that they could attend school,” Children’s Health Defense General Counsel Kim Mack Rosenberg this week told the new ACIP members.

by Brenda Baletti, Ph.D.

JUNE 27, 2025

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Children’s Health Defense (CHD) called on the CDC’s new vaccine advisory committee to change its best practices guidelines so physicians and school officials can’t use the guidelines to “recklessly restrict medical exemptions” from school vaccine mandates.

CHD General Counsel Kim Mack Rosenberg appealed to the Advisory Committee on Immunization Practices (ACIP) during the public comments section of Wednesday’s meeting.

ACIP’s guidelines, finalized in 2014, are not exhaustive and only broadly define contraindications and precautions for vaccines — they can’t capture all of the reasons a child may need a medical exemption, Mack Rosenberg said.

The document includes a table (page 54) with a partial list of contraindications and precautions for commonly used vaccines. For example, a person who is severely immunocompromised is advised not to take the dengue vaccine, and anyone who has experienced an anaphylactic reaction to a previous dose of any vaccine is advised to take precautions when taking any type of vaccine in the future.

The guidelines also include a table of conditions (page 63) of “incorrectly perceived” contraindications or precautions. For instance, the guidelines state that having a fever, a seizure or collapsing within 48 hours of receiving a DTaP vaccine does not qualify as a contraindication.

However, the guidelines also state that the decision to administer DTaP to a child with a suspected neurological disorder should be made on a case-by-case basis (page 61).

Medical exemptions should be based on clinical judgment, Mack Rosenberg said. But too frequently, doctors fear negative blowback if they write exemptions. And often when they do provide an exemption, “many states and schools are overriding treating physicians’ clinical judgments, and limiting exemptions to only those based on reasons explicitly listed in your non-exhaustive tables or, going even further, accepting only anaphylaxis as a valid exemption, ignoring other serious risks or reasons that a vaccine might need to be deferred.”

The formation of a new committee offers an opportunity to address this problem, she said. She urged members to change the guidelines or issue a clear public statement on the website clarifying that:

• The Centers for Disease Control and Prevention (CDC) is not authorized to give medical advice about what an individual child needs to stay safe.
• The guidelines are not exhaustive and cannot define every reason for a medical exemption.
• Only treating physicians, using CDC guidance, other evidence, patient and family history, clinical judgment, and any other information relevant to a child’s health, should determine if an exemption is warranted.

“The ACIP must act now to prevent continued harm,” Mack Rosenberg said. “Without your action, misapplication of ACIP’s guidelines will continue to have devastating consequences.”

She shared the example of Sarah Doe, whose New York school district continues to deny a medical exemption for the third hepatitis B (Hep B) shot after seven doctors and medical practitioners said the teen shouldn’t get the vaccine due to her serious medical conditions.

Sarah has been diagnosed with multiple health issues, including acute autoimmune hypersensitivity reaction, a history of severe vaccine reactions, and acquired von Willebrand disease, a rare bleeding disorder.

Her contraindications are so severe that even a walk-in clinic — where Sarah went alone to get vaccinated, desperate to return to school — refused to vaccinate her.

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Yet, the school district and the state of New York continue to deny her medical accommodation for the Hep B vaccine because her conditions aren’t listed by ACIP as a clear contraindication.

“Sarah is not alone,” Mack Rosenberg told the committee. “CHD and the attorneys with whom we work get calls like this every week.”

She said children are being deprived of federally protected disability protections. As a result, “some have been badly injured after they were forced to take vaccines against medical advice so that they could attend school.”

Mack Rosenberg said narrow interpretations of the ACIP guidelines are being used as a weapon against physicians who write medical exemptions. States have threatened doctors’ licenses when they don’t think a recommended exemption meets the criteria.

“Clarification of ACIP guidelines will protect children like Sarah, uphold physician autonomy, and ensure exemptions reflect individualized medical needs, not bureaucratic overreach,” she said.Related articles in The Defender

• Mom, Teen Sue School That Refused to Grant Hep B Vaccine Medical Exemption
• CDC’s New Vaccine Advisers Vow to Study Cumulative Effect of Childhood Vaccine Schedule
• New York’s Attack on Medical Exemptions Gives School Officials Power to Override Doctors on Vaccines
• Exclusive: How an ‘Extraordinarily Good Physician’ Lost Her License for Protecting Medically Vulnerable Children From Potentially Harmful Vaccines

Brenda Baletti, Ph.D.

Brenda Baletti, Ph.D., is a senior reporter for The Defender. She wrote and taught about capitalism and politics for 10 years in the writing program at Duke University. She holds a Ph.D. in human geography from the University of North Carolina at Chapel Hill and a master’s from the University of Texas at Austin.