By RMV Staff | Rocky Mountain Voice
When President Donald Trump signed an executive order establishing a new federal “Gold Standard” childhood vaccine schedule this week, it marked a major shift in federal vaccine recommendations.
The administration’s new framework reduces the number of diseases for which vaccines are routinely recommended for all children, moves several vaccines into high-risk or shared clinical decision-making categories, and encourages greater parental involvement in vaccination decisions.
But for Colorado families, the announcement raised an immediate question: If the federal government has changed its recommendations, why haven’t Colorado’s school vaccine requirements changed?
The answer lies in Senate Bill 26-032, legislation passed earlier this year that was designed to prevent Colorado from automatically adopting future changes to federal vaccine guidance.
Rather than relying exclusively on federal recommendations, the law allows Colorado health officials to consider guidance from additional professional medical organizations when making vaccine policy decisions.
That choice has taken on new significance now that the Trump administration and Colorado officials are moving in different directions on childhood vaccine policy.
What changed under Trump’s executive order?
Under the new federal recommendations, vaccines against 11 diseases remain routinely recommended for all children: measles, mumps, rubella, diphtheria, tetanus, pertussis, polio, Haemophilus influenzae type B, pneumococcal disease, human papillomavirus and varicella.
Other vaccines have been shifted into categories based on individual risk or decisions made between parents and healthcare providers.
Previous routine recommendations vs. Trump’s new federal recommendations
| Previous routine recommendations | New federal recommendations |
| Hepatitis A routinely recommended | Shared clinical decision-making and/or high-risk groups |
| Hepatitis B routinely recommended | Shared clinical decision-making and/or high-risk groups |
| Annual influenza vaccine routinely recommended | Shared clinical decision-making |
| COVID-19 vaccine routinely recommended | Shared clinical decision-making |
| Rotavirus routinely recommended | Shared clinical decision-making |
| Meningococcal vaccines routinely recommended by age/risk | Shared clinical decision-making and/or high-risk groups |
| Combination MMR vaccine | Separate measles, mumps and rubella vaccines when single-antigen products become available |
| Multiple vaccines may be administered during the same visit | Administration at separate medical visits encouraged when possible |
The order recommends that measles, mumps and rubella eventually be administered as separate vaccines rather than the combined MMR shot once those products are available in the United States. It also encourages spacing childhood immunizations across separate medical visits when possible.
The administration has also encouraged states to review their own school vaccine mandates in light of the new recommendations.
Why SB26-032 matters
One misconception surrounding Senate Bill 26-032 is that Colorado replaced the Centers for Disease Control and Prevention with the American Academy of Pediatrics as the state’s vaccine authority.
That is not what the law does.
Instead, SB26-032 broadened the sources Colorado may consider when establishing vaccine policy.
The State Board of Health may weigh federal guidance alongside recommendations from organizations including the American Academy of Pediatrics, the American Academy of Family Physicians, the American College of Obstetricians and Gynecologists and the American College of Physicians.
In practical terms, however, the law means Colorado is not required to automatically mirror future federal changes.
That is the key distinction now confronting Colorado parents.
President Trump has established a new federal direction emphasizing fewer universal recommendations and greater individualized decision-making. Colorado law gives state officials the ability to continue looking to other medical organizations even when their recommendations differ from Washington’s.
Colorado is also fighting the federal changes in court
The divide goes beyond state legislation.
Colorado is participating in litigation involving an earlier federal vaccine schedule that closely resembles the recommendations contained in Trump’s latest executive order.
The January 2026 federal schedule reduced the number of diseases targeted by routinely recommended vaccines from 17 to 11. A federal district judge later stayed those changes, finding that challengers were likely to succeed in arguing that the CDC’s process violated federal administrative law.
Colorado later joined other states in urging the First Circuit Court of Appeals to keep that block in place and is also involved in separate litigation challenging the federal schedule and changes to the Advisory Committee on Immunization Practices.
The result is an unusual political and legal situation: the Trump administration is asking states to consider a new federal vaccine framework while Colorado officials are helping defend a court order blocking an earlier version of substantially similar changes.
Why critics say SB26-032 raises new questions
Supporters of SB26-032 argue the law protects Colorado from abrupt changes in federal policy by allowing state officials to consult multiple professional medical organizations.
Critics argue it raises a different question: Who should have the greatest influence over Colorado’s vaccine policy if federal recommendations are no longer the automatic benchmark?
That debate intensified after organizations including the American Medical Association and American Academy of Pediatrics criticized Trump’s new recommendations.
The AMA warned that changing the established schedule without what it considers sufficient evidence could undermine confidence and place children at risk. The AAP similarly criticized the administration’s approach and continued to support broader childhood vaccination recommendations.
But critics of those organizations have also raised questions about their financial relationships with pharmaceutical companies.
According to an Aug. 11 report from Just the News, the AMA licenses physician profile information that pharmaceutical companies can combine with prescribing datasets for marketing purposes. The outlet reported that the AMA had total revenue of more than $540 million in 2024 and cited historical pharmaceutical grants received by the organization.
Just the News, citing Undark Magazine, also reported that the American Academy of Pediatrics accepts corporate sponsorships and that major pharmaceutical companies including Pfizer, Merck, Moderna and Sanofi have participated in an AAP corporate donor summit. The precise amounts of those corporate donations were not disclosed in the article.
The AMA says it does not collect, license or sell physician prescribing data, although the organization does license physician profile information.
The AAP, meanwhile, maintains that its vaccine recommendations are based on scientific evidence and disease risk and has rejected the administration’s criticism of the existing schedule.
Those financial relationships do not by themselves establish that pharmaceutical companies control vaccine recommendations. But for critics of SB26-032, they add another layer to the debate over whether Colorado should give increased weight to private medical organizations at the same time the federal government is moving toward a different model.
What does this mean for Colorado parents?
Parents who prefer President Trump’s new federal recommendations can discuss those options with their healthcare provider.
But families need to understand that a physician’s vaccination plan and Colorado’s school-entry requirements are separate issues.
Following the federal recommendations alone does not necessarily satisfy Colorado’s immunization requirements for school attendance.
For now, Colorado’s requirements remain in place.
Colorado’s school immunization requirements currently include:
- Hepatitis B
- Diphtheria, Tetanus and Pertussis (DTaP)
- Haemophilus influenzae type b (Hib)
- Polio (IPV)
- Pneumococcal conjugate vaccine (PCV)
- Measles, Mumps and Rubella (MMR)
- Varicella, or chickenpox
- One dose of Tdap before seventh grade beginning with the 2026-27 school year, a timing shift from the previous sixth-grade requirement
The Colorado Department of Public Health and Environment has stated that recent changes to federal vaccine recommendations do not change Colorado’s required vaccines.
That creates a potentially important issue for parents who want to follow the federal schedule.
For example, hepatitis B has been moved out of the federal all-children category and into high-risk or shared clinical decision-making categories, but it remains part of Colorado’s school immunization requirements.
A parent may therefore choose to follow the new federal recommendation medically while still needing to address Colorado’s separate school requirements.
What if parents don’t want to follow Colorado’s requirements?
Colorado continues to recognize both medical and nonmedical exemptions.
Medical exemptions require a Certificate of Medical Exemption signed by a licensed Colorado healthcare provider.
Parents seeking a nonmedical exemption based on religious or personal beliefs have two options. They may have an appropriate healthcare provider sign the state’s exemption certificate, or they may complete Colorado’s online immunization education module and obtain a Certificate of Nonmedical Exemption without a provider’s signature.
Parents generally submit the required exemption documentation to their child’s school.
Bottom line
President Trump’s executive order sets a new federal direction on childhood vaccines, but it does not rewrite Colorado law. It directs federal agencies to advance the recommendations within existing authority, encourages states to consider changing their own requirements, and gives a federal task force 90 days to develop implementation plans.
Colorado, meanwhile, wrote SB26-032 specifically so state officials would not have to follow federal changes automatically. The law lets the state weigh guidance from federal agencies alongside recommendations from private medical organizations, some of the same ones now opposing Trump’s new approach.
For Colorado parents, that means the federal recommendations may have changed, but the requirements facing families here have not.