Search:

A summary of presentations from the weekly Summit partner webinars

October 30, 2025 – The latest Summit Summary

Implications of ACIP Changes on Access to Vaccinations in Pharmacies – Allison Hill, PharmD, RPh Director, Professional Affairs at American Pharmacists Association (APhA); Michelle Cope, Director, Federal and State Pharmacy and Regulatory Affairs at National Association of Chain Drug Stores (NACDS); Hannah Fish, PharmD, CPHQ, Senior Director, Strategic Initiatives at National Community Pharmacists Association (NCPA)

Allison Hill, PharmD; Michelle Cope; and Hannah Fish, PharmD, gave an update about how ACIP changes have affected access to vaccinations in pharmacies.

VIEW SLIDES

Allison Hill – PharmD, American Pharmacists Association
The American Pharmacists Association (APhA) is the largest pharmacist association in the United States and represents over 340K pharmacists, 30K student pharmacists, and 400K pharmacy technicians. Pharmacists and pharmacy personnel are dedicated to meeting immunization needs and protecting the community from vaccine-preventable diseases. Last season, pharmacy personnel administered over 93% of adult vaccine doses for COVID-19, 64% of adult vaccine doses for influenza, and 95% of older-adult vaccine doses for RSV.

Changes for the 2025-2026 Season
Based on the threat of removal of COVID-19 vaccine from ACIP immunization schedules, and the resulting inability for pharmacists and pharmacy personnel to administer the vaccine, 25 states have acted to preserve COVID-19 access. This means that pharmacists’ ability to administer vaccines is not uniform across the country; rather, it is dictated by state law and regulation.

  • Across the 50 states, the conditions that affect whether pharmacists can administer vaccine vary and include:
    • Schedules/recommendations
    • Approvals
    • Statutes/regulations
    • Temporary orders
    • Statewide protocols
    • Standing orders
    • Prescription requirements
  • Permanent changes, reflected in state statutes and regulations will take some time.

Pharmacy Is United with One Voice
APhA is leading the pharmacy-based Vaccine Access Work Group, a coalition of diverse pharmacy organizations. The group released guiding principles in October 2025 to address ambiguity in state policymaking regarding pharmacy personnel-administered vaccines.

The guiding principles — which address areas such as authorization, definition of eligibility, training, and payment/coverage — are directed to several groups:

  • State policymakers and legislative staff considering how to craft or revise legislation
  • Boards of pharmacy and public health agencies as they update regulations or issue guidance
  • State pharmacy associations as they engage in legislative advocacy and policy education
  • Vaccine access advocates and public health partners

Vaccine Access Maps
APhA has interactive pharmacy vaccine access maps (vaccineconfident.pharmacist.com) that allow users to search for pharmacies that offer immunization services. There is also a provider map that includes filters for social vulnerability, medically underserved areas, and health professional shortage areas.

Michelle Cope – National Association of Chain Drug Stores
The National Association of Chain Drug Stores (NACDS) believes that pharmacists should be able to initiate and administer vaccines according to the standard of care, consistent with how other vaccine providers practice. For that reason, the pharmacy community supports changing state pharmacy practice laws to de-link pharmacist immunization authority from the vaccine recommendations of outside entities.

Pharmacists’ authority to deliver vaccine services, and the level of services available, varies from state to state. And that authority may be linked to ACIP recommendations, CDC approval, and the CDC vaccine schedule. So, if processes lag, patient access can be complicated.

COVID Vaccine Timeline for the 2025-2026 Season
For this season, the COVID vaccine was approved on August 27; ACIP did not convene to consider updating the recommendation until September 19; and CDC did not post the updated vaccine schedules until October 6.

  • The pharmacy community scrambled to offer temporary solutions that would simplify access and enable the public to receive vaccinations at pharmacies without a prescription, but it is not a long-term solution.
  • Now that ACIP recommendations have been incorporated into the childhood and adult vaccine schedules, pharmacists are able to initiate and administer vaccines in accordance with state laws.

Hannah Fish – PharmD, CPHQ, National Community Pharmacists Association
The National Community Pharmacists Association (NCPA) represents nearly 19,000 independent community pharmacies and nearly two-thirds of those are in rural communities serving patient populations of 50K people or fewer. So, the effects of ACIP’s recommendations really affect a primary access point for immunizations and healthcare in these communities.

Partnerships
The independent community pharmacies represented by NCPA are eager to partner with:

  • Schools, helping school nurses and clinics with immunization
  • Employers that can facilitate immunization clinics at their organizations

Billing and Payment
Some of the ACIP recommendations are tied to how patients are insured and covered for whether they can get vaccines for free or with no copay or no cost sharing, and pharmacies are working to figure out the payment mechanism(s). Complicating factors include:

  • Pharmacy has historically been paid using the pharmacy benefit, but vaccines split the gap of medical coverage: the pharmacy benefit and the medical benefit.
  • In the cases of Medicare versus Medicaid, or commercial versus the Vaccines for Children program, the question remains: How can we ensure that all providers are being adequately compensated for services and product?
  • A majority of independent community pharmacies service long-term care and skilled facilities, which adds to the complications of billing practices, based on classifications and types of stays.

QUESTIONS & ANSWERS

Q: With shared clinical decision making, or what they now call individual-based decision making, what does this extra step mean for the pharmacy community? How much time are you having to spend to put this step in? And what guidance are you giving to pharmacists about that process of shared clinical decision making, as well as what happens when there is separation in guidance? For example, between the CDC guidance, AAFP, AAP, and ACOG.
Michelle Cope (NACDS): There are questions around what this means. It’s not an unfamiliar concept: This is not the first vaccine that has had shared clinical decision making. The good thing, especially in the pharmacy setting, is that, when you have a lot of the patients coming in and getting vaccines, they’re initiating it. They know about the vaccine, they want the vaccine, and oftentimes, the vaccine appointments are being scheduled online. That’s a really great opportunity to present the vaccine information sheet [at scheduling]. You’re reading through and understanding: Here is all the information that one might have questions about, and it’s talking about potential side effects, and things like that. And then, when the patient comes into the pharmacy, they also are having the conversations with the pharmacist (e.g., “Do you have any questions about your vaccines?”) So, in the pharmacy setting, it’s a very feasible thing. We’re familiar with how to do it, and pharmacists across the country, when they’re providing these important services to patients, are having those discussions. I recall hearing during the ACIP meeting, the intention behind that was to promote discussion, and I think we’re doing a good job at that.
Q (follow-up): Hannah, thinking of the community pharmacists, what if there’s not a lot of online scheduling? What if it’s a walk-in into a rural community pharmacy? How does that shared clinical decision making impact that situation?
Hannah Fish (NCPA): A good majority of our membership has also started to adopt this appointment-based model for scheduling immunizations, but we do recognize that there are patients, especially in our more rural communities, that don’t have internet or online access. So, to echo what Michelle said, it’s pretty much business as usual. Shared clinical decision making should not look any different from any other type of vaccine recommendation, as far as the experience that the patient has. No matter what the vaccine is that’s recommended and, being able to provide the VIS to the patient to answer any questions, to double checking whether they have any contraindications or reasons not to be vaccinated, that — functionally — should not look any different to a patient, whether it’s your routine flu vaccine, or if it’s now COVID under shared clinical decision making. So, in terms of how that looks from a pharmacy standpoint and from a timing standpoint, it doesn’t adjust for them that much, either. So, it’s potentially heightened the need to have more of a conversation. As we saw, that was emphasized in the ACIP meeting. That’s really what the committee was talking about, is making sure patients understand the risks and benefits for them. But that’s adding a couple of seconds to a conversation, that’s in addition to what we’ve already been doing for years now.
Q (follow-up): What happens when the recommendations differ?
Allison Hill (APhA): I want to echo what Michelle and Hannah just said, but then also add that pharmacists are trained to have these discussions, so this is not new. We’ve been doing it for years, and it’s a part of our training. We collaborated with the Common Health Coalition on a shared clinical decision making resource. To the second part of your question, we have been addressing these issues, and we think that we’ll be fully able to prepare people to get their vaccinations.
Q (follow-up): What guidance are you giving pharmacists when the recommendations are beginning to…diversify?
Allison Hill (APhA): We are educating our members to make sure that they can look at different guidelines and recommendations. [For years, pharmacists have looked at] different recommendations and guidelines for other disease states, such as hypertension and diabetes, and pharmacists are trained to address all these different types of guidelines. So, we’re able to address the fact that we have different guidelines for these vaccinations and can address that with our patients.
Michelle Cope (NACDS): As a trade association, we don’t advise our members one way or the other. Our members are pharmacy companies.
Hannah Fish (NCPA): I’ll just echo what Allison said: Just because we have differing vaccine recommendations this year, that doesn’t diminish the fact that community pharmacists, pharmacists in general, are highly trained individuals with a vast knowledge of clinical information, and they are making that discernment with other disease states, too. So, just to echo the point that we’re using our clinical decision making when there are differing guidelines.
Q (follow-up): Pharmacists were specifically called out as being eligible for shared clinical decision making. Is it true that pharmacy technicians cannot provide shared clinical decision making?
Allison Hill (APhA): That is correct. For shared clinical decision making, it is only the pharmacists that can provide that. And just as a reminder, pharmacy technicians and student pharmacists practice under the supervision of a pharmacist, and that’s why the pharmacist is the one that can provide that shared clinical decision making.

Q: Among the states that have made changes to allow pharmacists to administer COVID vaccines, do you know how many were changes to legislation and how many were just temporary changes?
Allison Hill (APhA): From what we’ve been watching, most of those are temporary changes with the ability to be put in legislation, so we’re still waiting to see what happens to make sure that it is put into permanent legislation, and then that’ll go to regulations for pharmacists and pharmacy personnel.
Michelle Cope (NACDS): I think the only states that did something permanent were Arizona, which was quick to update their rules; New Jersey did something quickly; and there were a few states where the fix was [something like] adjusting a statewide protocol, and so those were also made quickly. But most others were either an executive order or some sort of temporary workaround. But you still have the underlying — most of the time it’s in statute — language that needs to be modernized.

Q: ACIP just added a pharmacist, Dr. Hilary Blackburn, to the committee. This is a very important addition. Her contributions to the last ACIP meeting were very helpful. Is she a member of any of your groups, in that coalition, etc.? And have you been able to engage her in support of the mission of vaccine delivery and improving access by pharmacists?
Allison Hill (APhA): Dr. Hilary Blackburn is a long-standing member of the American Pharmacists Association and other pharmacy associations, and she’s had leadership within APhA and has received the APHA Foundation Pinnacle Award for her work with underserved communities and increasing access to medications and services. And we are super proud that she is a pharmacist and on the ACIP committee.
Q (follow-up): Does NCPA or NACDS work with Dr. Hilary Blackburn at all?
Michelle Cope (NACDS): Our members are pharmacy companies.
Q (follow-up): Is there any opportunity for using Dr. Blackburn to move some of the decision-making processes that are going on with ACIP that, obviously, is now under some challenge?
Allison Hill (APhA): We want to make sure that there’s no conflict of interest, but where we can educate and provide awareness, we are available to do so.

Q: Can you share the guidelines about providing vaccines in community? Do they have to meet any specific requirements?
Hannah Fish (NCPA): There aren’t any specific guidelines that we can point to to say, “This is the exact protocol that community pharmacy has to provide.” But most states, I believe, require some level of education — and I’ll let Allison talk about their immunization program — but it’s over 20 hours of continuing education credit, plus live training for the vaccine techniques. So, there are all those lessons learned that our pharmacists, our technicians, and students get from that education. And then there are general policies and procedures in place that our pharmacies have. This would go for any other entity that is storing and handling vaccines, that is doing temperature tracking and monitoring, and making sure we’ve got the integrity of the vaccines in place, plus the documentation, and making sure that we use the VIS statement. Even reporting to the immunization registry after the fact. So, pharmacy is one of the most highly regulated healthcare professions out there, so while there might not be an actual guideline, per se, trust me we are crossing our t’s and dotting our i’s in this industry and doing everything that we can to make sure that we’re doing everything right.

Q: Do you have to check off as a pharmacist that you’ve done clinical decision making with the patient in order to ensure payment?
Michelle Cope (NACDS): There’s not a regulatory requirement around that. I think that different pharmacy practices will have different approaches for how they accomplish that and whether there’s documentation, and it’s probably going to differ across [payers, too]…. I don’t know that there’s a standard answer for that.
Hannah Fish (NCPA): I can’t speak for the rest of the healthcare providers who are on this call, but I’m not aware that anyone else has a requirement to check something off or do something. I know in visits, in terms of billing, you will enter codes for what services you provided or not but remember, in pharmacy, we largely have not been able to bill for our services, or we haven’t been able to bill in a large majority of our states for the counseling that we’re providing and the questions that we’re answering. That’s starting to change. I know there are some states now that are allowing for that payment or reimbursement for the time that is being spent, even if someone does not actually get a vaccine that’s administered. But functionally, if there are any requirements, and I’m not advocating for this or condoning this in any way, those requirements are provider or payer required, and so far, we haven’t heard any requirements from the payers that there’s any sort of special documentation that’s needed.
Allison Hill (APhA): We do want to emphasize that we would like that not to be a requirement. Pharmacists have been trained and able to provide that, but without vaccine counseling services payment and other payment parity, we would not want an extra step just for administration of vaccines.

Q: When you do your mobile clinics, or other things you are doing as pharmacists in the community, are there things that we can share out to the Summit partners, so that they know what you all are doing and continue to collaborate?
Hannah Fish (NCPA): Absolutely. I would point you all to our website. We have a variety of resources that we’ve created. Most of them are geared towards pharmacists for what they do and how they should do things, but honestly, a lot of those resources then link back to the resources provided from Immunize.org and the Summit, so we love borrowing whatever everyone else has created, because it’s such great material. But a couple of the things that we’ve created: we have a guide to implementing vaccine services in community pharmacy that goes through all the steps to consider, you can see what we’re encouraging our members to do, as far as how they offer their vaccine recommendations and their support, and how they set up clinics and work with employers; and we have recently created some short videos that help pharmacists identify and target particular populations who might be at increased risk for needing certain vaccinations to prevent those vaccine-preventable diseases. We also have some podcasts that we’ve recorded in the past year that have really emphasized some of the nuances of immunizing patients from the community pharmacy perspective.

Q: Anything from APhA that you could share?
Allison Hill (APhA): Sure, I’ll touch back onto the training. Pharmacists are required to take both a didactic and a hands-on training to provide vaccination services. APhA has a certification for pharmacy technicians, it’s didactic, and they must show the pharmacist that they’re under supervision and have proper technique on how to administer those vaccinations. And one thing that is probably different from other providers is most states do require pharmacists [to] take immunization continuing education as part of their requirements to renew their license, and that’s something [to show] that they’re staying up to date, still knowledgeable about the best practices and the new updates. But we do have quite a few education services that we offer to our members, including the student pharmacist, the pharmacist, and the pharmacy technicians. And just to go back to the second part of the question, it was [being able to learn and provide information about] where pharmacies are able to have mobile vaccination clinics. Most pharmacies, when you call them or reach out to them or go on their websites, they do provide that information, and if anyone wants to collaborate and do a clinic, you can partner with them, because quite a few go into the community and provide those clinics.

Q: And Michelle, I imagine your member pharmacies probably do similar things as well as going into the community to provide vaccines, right?
Michelle Cope (NACDS): Sometimes they will do employer programs, and we’ll be invited in to come and make vaccines available.
L.J Tan (NAIIS, Immunize.org): I think one of the things the Summit’s trying to focus on is re-energizing the “place of employment” vaccination opportunity. So, with COVID now sort of in the rearview mirror, and people are beginning to return to work, that might be an opportunity for place-of-employment vaccinations, as well.

Q: The principles that your coalition has put together, is that published anywhere that we can share to everybody, so people can see what your coalition has come up with, with regards to principles for pharmacy practice immunizations?
Allison Hill (APhA): There was a QR code on the slide I shared that was linked to our website: Pharmacist.com. You can read the press release, and then also a link to the actual principles that everyone can use. Feel free, whenever you’re going to advocate for vaccine access, to use that to talk about pharmacists’ authority to vaccinate.

Q: There have been proposals for a waiting period before someone gets vaccinated. So, for example, you want to get a vaccine, someone says you’ve got to wait and think about it and come back in two days. Any thoughts from any of you regarding what that would mean to pharmacy immunizations? Especially since you have multiple ways of doing this — you’ve got walk-ins, which I can imagine would be a little more challenging, but you also have scheduled appointments — any comments on the waiting period before a person can get vaccinated?
Michelle Cope (NACDS): I would first ask where you are seeing that? I think we can all understand that having to wait, when you’re already saying, “I want this vaccine,” can dissuade someone. It might become, “Oh, never mind, I’m not going to come back for it.” That’s a challenge, and that’s something that we would not want to see. We want people who want vaccines to be able to get the vaccines without delays. So, I think it harms access for people that want the vaccine, for people that understand the value of the vaccine, and I don’t think that makes sense.
Allison Hill (APhA): As a practicing pharmacist that has had many conversations with patients over whether to have a vaccine, sometimes it may take two or three different conversations over a period of days or weeks in order to have someone want to get the vaccine. Requiring them to wait an extra step, that would cause a little bit of havoc and headache and would probably prevent a lot of people from even wanting the vaccine and, [then there would be] lower uptake from that.
Hannah Fish (NCPA): I’ll just echo what Michelle and Allison both said. I think the whole idea of waiting is just going to impede access, and especially if we think about our rural communities and the membership that NCPA represents. You know, some people make a day trip of going to their pharmacy, or there is a significant travel time to get to that location, so to make them readjust their day again to seek care is not ideal.

BACK TO TOP

Announcements
  • A registration-required, 90-minute webinar, “Payment Challenges in the New Immunization Environment,” is scheduled for Thursday, November 13, 2025. The panel will include representatives from America’s Health Insurance Plans, the Alliance of Community Health Plans, the Common Health Coalition, the National Association of Community Health Centers, and Avalea Health. There will also be a short update from the Adult Vaccine Access Coalition to highlight new legislation going through ACIP.
  • Save the date for the 2026 National Adult and Influenza Immunization Summit in-person meeting: May 19 – 21, 2026 at the Crowne Plaza Atlanta Perimeter at Ravinia in Atlanta, GA.

BACK TO TOP

Search: