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Public Comments to ACIP: 5 Recommendations for Updating Guidelines

Published April 16, 2025

Microphone in foreground of blurred auditorium

Today, the Centers for Disease Control and Prevention’s (CDC) Advisory Committee on Immunization Practices (ACIP) convened to review scientific data and review vaccine recommendations. The advisory committee is scheduled to meet three times each year. As part of public comment, Alliance Director of Health Programs Katrin Werner-Perez and Alliance President and CEO Sue Peschin, MHS, each delivered public comment to the group.

Werner-Perez:

Good afternoon. My name is Katrin Werner-Perez, and I serve as the Director of Health Programs at the Alliance for Aging Research. Thank you for the opportunity to provide comments today.

Vaccines represent one of our most effective tools in preventing disease and improving quality of life, especially for older adults. Recognizing their importance, we ask ACIP to consider updating guidelines to reflect the following five recommendations in the interest of public health:

  1. We strongly support lowering the risk-based age recommendation for RSV vaccines to adults aged 50 and older. RSV, or respiratory syncytial virus, causes approximately 42,000 hospitalizations annually in adults aged 50 to 64, and contributes significantly to mortality rates. Moreso, adults with preexisting medical conditions are at a higher risk for severe complications. Lowering the RSV vaccination age would offer earlier, broader protection, reducing disease burden and healthcare costs.
  2. Second, we would like to see the addition of a vote to expand the routine age-based recommendation for adults aged 60 to 74. Recent data indicates there are disparities in RSV vaccination rates between populations. A routine age-based recommendation could significantly reduce these disparities and improve health equity.

    In fact, the RSV working group’s own data from the June 2023 ACIP meeting showed that a lower age-based recommendation for the RSV vaccine might “increase equity by decreasing the RSV burden among persons from racial and ethnic minority groups and in persons with lower income levels.”
  3. Third, we commend ACIP for lowering the age recommendation for pneumococcal vaccines to adults aged 50 and older. Clear, accessible information must continue to be provided to healthcare providers and the public to maximize uptake and reduce pneumonia-related complications.
  4. Fourth, we urge the committee to continue to prioritize measles vaccination. According to the CDC, since January 1, 2025, over 700 cases of measles have been confirmed. 12% of these cases have led to hospitalization, and three deaths have been reported. Measles complications pose severe risks, especially to older adults. Maintaining high vaccination rates across all age groups is essential to preventing outbreaks and protecting vulnerable populations. We also encourage further research into whether measles booster vaccines should be considered for older adults.
  5. And finally, continued transparency and public engagement in ACIP meetings are essential to maintaining trust and credibility in vaccine policy. We ask that ACIP continue public participation and open comment periods at all meetings.

Thank you again to ACIP and the CDC for your ongoing efforts to protect public health.

Peschin:

Good afternoon. My name is Sue Peschin, and I serve as the President and CEO at the Alliance for Aging Research. 

My colleague Katrin Werner-Perez outlined the Alliance’s requests for lowering the risk-based age recommendation for RSV vaccine and other issues, so I have just a few additional observations.

First, we were surprised to see votes on flu removed from the April meeting agenda and moved to June. 

The decision to remove or delay ACIP votes on flu vaccines is not inconsequential. A new Journal of Infection study found that increasing the vaccination rate by just 5% can lead to millions of fewer influenza cases and tens of thousands of fewer hospitalizations in a moderate severity season, especially in preschool children and adults 65 years and older. If ACIP does not vote on the Vaccines for Children program resolution in June, there will be no guarantee of free flu vaccines offered to children who need them this fall. We also encourage ACIP to offer preferential recommendations on higher-dose flu vaccines for older adults and specific high-risk groups. Yes, any flu vaccine is better than none, but the data clearly show higher-dose options are more effective for these groups.

Older adults also need updated COVID-19 vaccines ready before the fall. COVID-19 vaccination has been an incredible success story for public health—saving millions of lives. We ask the FDA to schedule its Advisory Committee review as soon as possible so that ACIP can vote on recommendations at its June meeting, if not before. 

Also, please keep the ACIP COVID-19 vaccine recommendation simple. If a whopping 74% of adults 18 and over have at least one condition that puts them at higher risk of severe illness from the virus, shifting to a risk-based recommendation is a recipe for mass public confusion that health insurance companies will leverage to save money. We don’t want that and don’t think you do either. 

Last, I want to express our deep appreciation for all of you—those who have dedicated your time, energy, and expertise to serving the American people. Whether you are career staff at the CDC or serving on the ACIP, we want you to know that we see you, we value you, and we thank you for your continued commitment to protecting public health.

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