As federal vaccine policy remains in flux, a new report from the Global Healthy Living Foundation (GHLF) urges state lawmakers to protect adults’ ability to get vaccinated by pharmacists at their local pharmacy. The report, Why States Should Protect Patient Access to Pharmacist Immunization During Federal Regulatory Uncertainty, finds that many state laws make pharmacist vaccination depend on action by the federal Advisory Committee on Immunization Practices (ACIP), an official publication of its recommendations, a state list, a protocol, or a prescription. When the federal process stalls, those dependencies can block pharmacy access to FDA-approved vaccines because pharmacists cannot immunize.

Written by Robert Popovian, PharmD, MS, GHLF’s Chief Science Policy Officer, the report documents how important community pharmacies have become to adult vaccination in the United States. It then lays out a ranked, three-tier legal framework that states can adopt now, without waiting for federal litigation to be resolved.

The timing reflects a year of federal disruption. In June 2025, the U.S. Department of Health and Human Services removed all 17 sitting ACIP members and began appointing replacements. In March 2026, a federal court stayed the challenged appointments and votes; the government has appealed, and the litigation is ongoing. The Centers for Disease Control and Prevention (CDC) canceled ACIP’s March and June 2026 meetings because of the litigation. According to the report, the hardest problem is prospective: who will review a new vaccine, a revised age group, or a future seasonal formulation in a timely way if the ordinary ACIP process cannot function consistently?

Key findings

  • Pharmacies are a primary site of adult vaccination.

  • Pharmacies are close and easy to reach.

  • Pharmacies are most available in underserved communities.

  • Extra regulatory or administrative steps instituted by states are associated with lower vaccine uptake.

  • Pharmacy vaccination costs less.

  • Missed doses are costly.

“Adults across the country have come to rely on their neighborhood pharmacist for flu, COVID-19, RSV, and shingles vaccines,” said Robert Popovian, PharmD, MS, Chief Science Policy Officer at the Global Healthy Living Foundation. “When state law ties that pharmacist’s authority to a federal advisory process that has been disrupted, patients can lose timely access to an FDA-approved vaccine for reasons that have nothing to do with science or safety. States do not need to wait for the courts or for Washington to fix this.”

During the COVID-19 pandemic, community pharmacists and their teams administered more than 270 million COVID-19 vaccine doses. A systematic review and meta-analysis found that vaccine coverage increased in every study in which pharmacists acted as educators, facilitators, or vaccinators.

A three-tier framework for states

The report ranks state options from the most durable reform to the minimum acceptable one. Each preserves individual clinical judgment and ordinary professional discipline.

  1. Preferred: an accepted standard of care. Authorize trained pharmacists to act consistently with professional competence, FDA status, current evidence, patient-specific factors, and enforceable safety duties.

  2. Fallback: an objective dual trigger. Authorize administration when either FDA status or an ACIP/CDC recommendation supports the relevant adult use.

  3. Minimum: one self-executing federal gate. If ACIP remains the trigger, make its recommendation the final step.

“The strongest approach is to let trained pharmacists practice to an accepted standard of care, as California now does,” Popovian said. “Restoring a lawful, credible, well-resourced ACIP process matters, but it is not a substitute for modernizing state scope-of-practice laws. The immediate job for states is straightforward: preserve qualified pharmacists’ legal ability to vaccinate adults safely, affordably, and without avoidable delay.”

The full report, available in English and Spanish, can be downloaded at https://ghlf.org/vaccines/. It builds on GHLF’s earlier policy research, including Removing Barriers to Pharmacy Vaccination: A Path to Better Health and Lower Health Care Costs (2024) and Enhancing Adult Vaccine Uptake: Challenges in Shared Clinical Decision Making and Risk-Based Recommendations (2025).

About GHLF

The Global Healthy Living Foundation is a U.S.-based, 501(c)(3) nonprofit, international organization whose mission is to improve the quality of life for people with chronic illnesses by advocating for improved access to health care through education, patient-centered clinical research, support, advocacy, and economic and policy research. GHLF is also a staunch advocate for vaccines. The Global Healthy Living Foundation is the parent organization of CreakyJoints®, the international, digital community for millions of people living with arthritis and their supporters worldwide who seek education, support, activism, and patient-centered research in English, Spanish, and French. In addition to arthritis and autoimmune disorders, GHLF supports dermatology, gastroenterology, neurology, cardiology, oncology, infectious disease, rare disease, and pulmonary patients through a host of different programs and activities which draw more than 700,000 patients a month to GHLF websites and create more than 10 million impressions a month on seven social media platforms. In 2024, GHLF had more than 1 million views and listens with its patient-centered audiovisual content, found on YouTube and podcast platforms. GHLF never asks the public for donations, receiving funding instead through governments, non-governmental organizations, foundations, industry, and family foundations. Visit www.ghlf.org for more information.

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