What President Trump's vaccine order means for Florida

By Jeff Scott, Esq.
FMA General Counsel

President Donald Trump signed an executive order on Aug. 10 directing the federal government to adopt a substantially narrower framework for routine childhood immunization recommendations. The order, titled “Delivering Gold Standard Childhood Vaccine Recommendations for Americans,” builds on a Jan. 2026 U.S. Department of Health and Human Services assessment comparing the U.S. childhood immunization schedule with those of other developed countries.

Under the order, vaccines are divided into three categories. Eleven vaccines are designated as recommended for all children: measles, mumps, rubella, diphtheria, tetanus, pertussis, polio, Haemophilus influenzae type B, pneumococcal disease, human papillomavirus (HPV), and varicella. The administration characterizes this as a reduction from the 18 diseases covered by the federal recommendations in 2024.

A second category consists of vaccines recommended for certain high-risk groups or populations: respiratory syncytial virus (RSV) monoclonal antibodies, hepatitis A, hepatitis B, meningococcal B, meningococcal ACWY, and dengue. A third category includes vaccines subject to shared clinical decision-making, under which vaccination decisions are to be made by parents and clinicians based on individual circumstances. This category includes hepatitis A, hepatitis B, rotavirus, meningococcal disease, influenza, and COVID-19.

The order also calls for significant changes in how childhood vaccines are administered. It states that the combined measles-mumps-rubella (MMR) vaccine should ultimately be replaced by three separate single-disease vaccines once such products are available in the United States. It further recommends, “to the maximum extent feasible,” that childhood immunizations be administered at separate medical visits. The administration says these changes are intended to give parents greater flexibility in deciding when and how their children are vaccinated.

Importantly, the executive order does not itself immediately eliminate vaccines from the federal vaccination schedule or prohibit physicians from administering them. Instead, it establishes the administration's preferred framework and directs federal agencies to take appropriate steps to advance it. The HHS Task Force on Safer Childhood Vaccines is given 90 days to develop plans addressing, among other things, the timing and sequencing of childhood vaccines, alternatives to combination vaccines, vaccine safety monitoring, and research into alternatives to aluminum-containing adjuvants.

For Florida physicians, one of the most important questions arising from President Trump's new executive order is whether the changes to the federal childhood vaccination recommendations will immediately alter Florida's school-immunization requirements. They do not.

Florida law independently establishes immunization requirements for children attending public and private schools. Section 1003.22, Florida Statutes, requires immunization against specified communicable diseases, including poliomyelitis, diphtheria, measles (rubeola), rubella, pertussis, mumps and tetanus, as well as other diseases designated by the Florida Department of Health. The statute also directs that the manner and frequency of immunization conform to recognized standards of medical practice.

Consequently, a change in the federal Centers for Disease Control and Prevention's (CDC) recommended childhood schedule does not, by itself, repeal or amend Florida's statutory school-entry requirements. Florida's requirements remain in effect unless the Florida Legislature changes the statute or the Department of Health changes applicable rules pursuant to its statutory authority.

This distinction is particularly significant because Florida already maintains its own immunization schedule for school and child-care purposes through the Department of Health's Immunization Guidelines for Florida Schools, Childcare Facilities, and Family Daycare Homes. Legislative analyses prepared in 2026 note that those Florida guidelines have remained unchanged since their adoption in 2013.

The executive order does, however, have the potential to generate future changes in Florida policy. The order directs the federal government to encourage states to review their immunization requirements in light of the revised federal recommendations. It also directs the U.S. Department of Justice to pursue appropriate legal challenges involving state laws that the administration believes conflict with federal constitutional or statutory protections concerning parental authority, religious liberty, disability accommodations, equal protection and related issues.

That does not mean that the federal government has presently invalidated Florida's school-vaccine laws. The federal government generally cannot change a state statute simply by issuing an executive order, and the order itself does not purport to preempt Florida's immunization requirements.

While Florida has taken steps to change the state’s immunization requirements by proposing a rule change to update the immunization and documentation requirements for school entry (the Department of Health held a rule development workshop on Dec. 12, 2025, to consider a proposal to eliminate the state rule-based school-entry requirements for four vaccines: hepatitis B; Hib; varicella; and pneumococcal conjugate), to date a Notice of Proposed Rule has not been formally published. The four vaccines remain required.

For Florida physicians, the practical takeaway is that there is no immediate change to the state's legal requirements for school vaccination. Physicians should continue to follow applicable Florida law and the current Florida Department of Health requirements when advising patients about school-entry immunizations. At the same time, physicians should expect further federal and state action as HHS, CDC, the Florida Department of Health, the Florida Legislature and potentially the courts address the consequences of the new federal recommendations.

The situation is likely to evolve rapidly. In particular, any future changes to the CDC's recommendations, Florida Department of Health rules, Florida statutes, or school-entry requirements should be evaluated separately rather than assuming that a change in one automatically changes the others.