Notes on the new Covid-19 vaccine rules

The Food and Drug Administration approved the 2025-2026 formulation of the annual Covid-19 booster today. As expected, the label limits approval to people over the age of 65 and younger people with underlying health conditions. The list of qualifying conditions is very broad, including common conditions like obesity, type 2 diabetes, and physical inactivity. ACIP normally also weighs in, but it's not clear to me whether that will happen this year. I expect the new formulation to be available in September.

The most common question I am getting right now is what this all means for access. Will people who do qualify actually be able to get vaccinated? Will people who are not eligible be able to get it anyways?

I think the answer to both of these questions is yes, with caveats. People who are eligible will likely still be able to get vaccinated where they normally get their seasonal vaccines, and people who are not eligible but willing to put in effort can probably find a way.

The real challenge will be navigating the system and dealing with uncertainties. Even if you technically qualify (and about a third of adults probably do under these broad conditions), you now have to figure out if you're eligible, understand what that means for how you get it, and manage potential confusion at the pharmacy. If you stop by CVS and say "I have a qualifying condition," is that good enough? These kinds of questions become real obstacles to uptake.

One group that particularly concerns me is healthcare workers. Based on the FDA labeling announced today, healthcare workers won't be able to get the vaccine unless they qualify under one of the health condition categories. This seems like a significant oversight for people caring for those who are more vulnerable, and are at high risk of exposure themselves.

For children, the situation is similar. Both Moderna and Pfizer products will only be available to children with underlying health conditions. Again, many children may qualify due to conditions like obesity, but parents will face the same navigation challenges as adults.

I definitely expect lower uptake this year because of these new policies. Last season, about a quarter of American adults got their annual Covid-19 booster, which is not as high as we'd like, but still meaningful. For comparison, flu vaccination rates tend to be around 45% for older adults. Many of those people who chose to get vaccinated last year may not have an easy path to do so this time.

This decision really comes down to limiting Americans' ability to make their own choices. Removing the option for people to get protected doesn't make sense to me. Think about all the people who might have good reason to want this protection: those who work in nursing homes, people caring for elderly family members at home, or anyone who simply wants to reduce their risk during a known period of elevated transmission. We're taking away choice from these people, and that concerns me.