Originally published by our sister publication Pharmacy Practice News
Hillary F. Blackburn, PharmD, MBA, the first pharmacist voting member of the CDC’s Advisory Committee on Immunization Practices (ACIP)—a position that industry leaders had advocated for—wasted no time in making her mark on the committee.
Participating in her first ACIP meeting on Sept. 19, just days after being named to the committee by Health and Human Services Secretary Robert F. Kennedy Jr., Dr. Blackburn was a leading voice in opposition to a proposal that would have required prescriptions for COVID-19 vaccines. The measure ultimately failed by the narrowest of margins, in a 6-6 tie.
Although the deciding “no” vote was technically cast by committee chair Martin Kulldorff, PhD (per ACIP rules, a tie is broken by the chair’s vote), Dr. Blackburn’s arguments about pharmacists’ accessibility in vaccination dispensing significantly shaped the debate.
“Pharmacists are licensed healthcare professionals… one of the only clinician types to complete a standalone national immunization delivery certificate,” said Dr. Blackburn, the director for medication access and affordability at Ascension, in Nashville, Tenn. “According to claims data for the 2024–2025 season, 90% of COVID-19 vaccines were given at pharmacies—27,569,515 doses out of 30,775,189. Requiring a prescription would create barriers for patients and risk deterring people who seek vaccination.”
She pressed the point with an anecdote about her own experience as a patient. “When I want to see my internist, I have to wait a year,” she told the committee. “And I can’t see them more than once a year. [Requiring a COVID vaccine prescription] is essentially going to be a barrier for people to have access to this vaccine, and that is not the role of ACIP.”
Dr. Blackburn’s concerns were echoed by other voting members. “Requiring a prescription is going to become a big barrier to administration of this vaccine. If a person wants it for himself, herself, or her children, they should be able to get it without a prescription,” said Cody Meissner, MD, a professor of pediatrics at Geisel School of Medicine at Dartmouth, in Hanover, N.H., and a former ACIP member recently reappointed by Mr. Kennedy.
“Approximately 30% of Americans don’t have access or ready access to a primary healthcare provider. In Texas and more rural states, it can be an even higher barrier,” said ACIP member Joseph R. Hibbeln, MD. “That [access gap] impairs the ability to have a risk–benefit discussion with a provider. This would present a significant barrier to implementing all of the good things we’ve discussed,” stressed Dr. Hibbeln, a former chief of the Section on Nutritional Neurosciences at the National Institutes of Health, in Bethesda, Md.
The debate also revealed how little some ACIP members understood about the practicalities of pharmacist-provided immunization. Retsef Levi, PhD, a professor of operations management at MIT Sloan School of Management, in Cambridge, Mass., suggested that requiring prescriptions would not meaningfully reduce access since, he assumed, pharmacists could still provide vaccines regardless.
“So, the requirement for informed consent is basically a requirement that some competent individual works through the risk–benefit ratio for that individual patient. And that individual patient is making an affirmative decision together with their healthcare provider … that this is the best path forward for them,” he said. “I prefer to err on the side of an actual prescription after a discussion with a licensed healthcare provider that is well qualified to serve in a partnership role with the patient. I don’t think [a prescription requirement] is going to lead to any access problem because most states have a solution. The states that don’t have a solution can either find a solution based on pharmacies or reject that.”
Dr. Blackburn corrected him, noting that pharmacists are not authorized to prescribe vaccines in all states. (The Public Preparedness and Emergency Act, extended through 2029, allows pharmacists to administer COVID-19 vaccines in all 50 states without a prescription, but it does not grant them prescribing authority. If a federal requirement for a prescription were to be imposed for the vaccine, then they might only be able to do so in states that grant pharmacists prescribing authority.)
“In some states, we can operate under a collaborative practice agreement, but it would be a barrier for access if a prescription was required,” she said. “Requiring a prescription, that would essentially eliminate the ability of pharmacists to provide COVID-19 vaccines in many jurisdictions. That’s not theoretical—it’s the reality of how our practice authority is structured.”
Another Voice Uplifting Pharmacists
Kelly Goode, PharmD, a professor of pharmacy at Virginia Commonwealth University, in Richmond, who spoke on behalf of the American Pharmacists Association (APhA), also stressed the importance of pharmacists as vaccine providers—and the connection with ACIP recommendations.
“In many states, the authority for pharmacists to give vaccines is based on an ACIP recommendation,” she told the panel. “So, if ACIP requires a prescription for the COVID-19 vaccines, then [pharmacists] may no longer be able to administer the vaccines without first having a prescription from a physician. Pharmacists are the most accessible healthcare providers, we have the most experience with COVID-19 vaccines, and we are well equipped to determine risk based on medications and health histories.”
Like Dr. Blackburn, Dr. Goode warned of the broader consequences of a prescription requirement. “Requiring a prescription for COVID-19 vaccine will decrease access for patients, will highlight healthcare inequities, especially for patients who may not have access to any other healthcare provider in their communities, and decrease individual patient choice. A prescription is not needed and will cause unnecessary steps to access.”
Dr. Blackburn was one of seven pharmacists on a list of recommended candidates sent to Secretary Kennedy by seven pharmacy organizations, including the APhA, the National Community Pharmacists Association, and ASHP in late August (Dr. Goode was another).
“Pharmacists across the country have demonstrated their capacity and effectiveness in ensuring access to care, particularly in underserved and rural communities. Patients identify pharmacists among their most trusted healthcare providers and routinely seek guidance from their pharmacist on the risks and benefits of vaccines,” the letter noted.