Update: CDC Issues Interim Guidance for 2026-2027 Influenza Vaccination Season

We are writing to provide an important update to our August 28, 2026 communication regarding ongoing uncertainty surrounding federal vaccine recommendations and their impact on pharmacy vaccine administration authority, standing orders, and protocols.

On September 1, 2026, the Centers for Disease Control and Prevention (CDC) issued new guidance entitled "Interim Clinical Considerations for the Use of Seasonal Influenza Vaccines in the United States." In this document, the CDC specifically addressed the ongoing legal uncertainty surrounding vaccine recommendations and clarified that, for purposes of the 2026-2027 influenza season, the seasonal influenza vaccination recommendations contained in the July 2025 CDC immunization schedule remain in effect.

The guidance states that routine annual influenza vaccination should continue as described in the July 2025 immunization schedule and that individuals should receive an FDA-licensed, age-appropriate influenza vaccine. The CDC further continues to recommend annual influenza vaccination for eligible persons and maintains its longstanding recommendations regarding vaccine administration, timing, special populations, and vaccine product selection.

This clarification is significant because it represents CDC's first direct statement addressing how the agency intends healthcare providers to interpret influenza vaccination recommendations while litigation concerning certain federal vaccine policy changes remains unresolved. Specifically, the CDC has indicated that the July 2025 influenza vaccination recommendations remain operative for the 2026-2027 influenza season.

The new guidance also reiterates several practical considerations for pharmacies, including:

• Routine annual influenza vaccination should continue in accordance with the July 2025 immunization schedule.
• Adults aged 65 years and older should preferably receive a high-dose, recombinant, or adjuvanted influenza vaccine when available.
• Most individuals needing only one influenza vaccine dose should ideally be vaccinated during September or October.
• Vaccination efforts should continue throughout the influenza season as long as influenza viruses are circulating and unexpired vaccine remains available.
• Persons with egg allergy may receive any age-appropriate influenza vaccine, including egg-based vaccines.

While this update provides important clarification regarding influenza vaccination recommendations, it does not fully resolve broader questions related to pharmacist vaccination authority under individual state laws. As discussed in our previous communication, pharmacist vaccine administration authority remains dependent upon applicable state statutes, regulations, Board of Pharmacy guidance, standing order requirements, collaborative practice provisions, and payer requirements. These requirements vary considerably by jurisdiction and should continue to be evaluated on a state-specific basis.

Accordingly, we continue to recommend that pharmacies:

• Review applicable state vaccine administration laws and regulations.
• Monitor communications from their State Board of Pharmacy and other regulatory agencies.
• Verify payer requirements when reimbursement may be tied to CDC or ACIP recommendations.
• Review existing standing orders, protocols, and vaccine administration policies for continued compliance.
• Consult legal counsel regarding state-specific questions involving vaccination authority or liability.

R.J. Hedges & Associates will continue to monitor federal litigation, CDC guidance, ACIP activities, and state regulatory developments. Should additional guidance be issued affecting influenza, COVID-19, or other vaccine administration authority, we will provide further updates.

References

• Congressional Research Service (CRS), Changes to CDC Vaccine Recommendations in 2025 and 2026 (Updated July 29, 2026). [congress.gov]
• U.S. District Court preliminary injunction discussed in American Academy of Pediatrics v. Kennedy and related summaries. [mha.org]

Disclaimer: This communication is intended for educational and compliance awareness purposes only and does not constitute legal advice. Pharmacies should consult qualified legal counsel and applicable state regulatory authorities regarding state-specific requirements.

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