Immunization programs have historically relied on aligned federal and state policy.1 The US Food and Drug Administration (FDA), Advisory Committee on Immunization Practices (ACIP), and Centers for Disease Control and Prevention (CDC) release vaccine regulatory decisions and recommendations, which states often reference in laws and regulations to govern clinician authority, insurance coverage, and, ultimately, vaccine access. Delays and the absence of updated ACIP recommendations early in the 2025-2026 viral respiratory season introduced uncertainty for states whose regulations explicitly reference federal guidance.2 These developments prompted varied state-level actions, both executive and legislative, affecting COVID-19 vaccination access, with long-term implications for future vaccine policy.3 This study analyzed state actions taken in 2025 that strengthened or weakened COVID-19 vaccination infrastructure and access.
