Executive Summary

• Recent membership and process changes to federal advisory committees (FACs) across the Department of Health and Human Services have highlighted the role of expert input in federal policymaking and the future of public health norms.
• FACs provide essential, external subject matter expertise that guides substantive and effective policy, crucial for protecting consumer choice and maintaining public trust.
• Impeding FAC operations at federal health agencies threatens consumer access to vital treatments and may erode public confidence in the health care providers and their regulatory institutions.

Introduction

Last week, leadership at the Food and Drug Administration announced during a meeting its “get away” from inviting outside experts to review and vote on individual drug recommendations, claiming that advisory committees are no longer needed. This statement follows the Department of Health and Human Services (HHS) Secretary Robert F. Kennedy Jr.’s unprecedented decision to dismiss all 17 members on the Advisory Committee for Immunization Practices back in June. Moreover, Secretary Kennedy accused the American Academy of Pediatrics of long-standing conflicts of interest, following the organization’s opposing vaccine recommendation. Together, these events highlight questions about the role of experts and advisory committees in federal policymaking and the future of public health norms.

Federal advisory committees (FACs) are designed to bring external, highly specific subject matter expertise into the policymaking process. While FACs and their supporting workgroups do not typically issue final rules or guidance, their work has historically been highly influential in shaping agency decisions. Given this importance, FAC members are subject to routine conflict of interest screenings, which include financial disclosures and a review of previous work experience. This process is crucial to preserving the integrity of committee recommendations and the federal agencies that adopt them. Ensuring that FACs adhere to these standards helps protect American consumers and maintains public confidence in their regulatory institutions.

Many advisory committees play a crucial role in public health policy, influencing a wide range of consumer choices regarding health care. More recently, discourse has centered around the availability and coverage of vaccines on the market. Although the agencies’ enforcement of conflict-of-interest standards is important, the tangible impact on consumer choice, as well as public trust in health care stakeholders, should be taken into careful consideration.

The Role of Federal Advisory Committees

Federal advisory committees combine the expertise of external stakeholders with the insight and authority of government officials. This process centers on periodic meetings among academics, industry leaders, government employees, and other qualified personnel to review relevant data and make recommendations on prospective policies. Although FACs are limited in the number of individuals who can make direct recommendations to the agency, the committees typically encompass a broad perspective informed by experts collaborating in established workgroups. Of note, FAC activities and materials are almost always made available to the public, promoting civic engagement and building trust. Bridging these entities – industry experts, government officials, and the public – assists in securing a diverse collection of credible ideas that are fundamental to effective policymaking.

Virtually all FACs operate under the Federal Advisory Committee Act (FACA). The statute mandates that advisory committees remain transparent, accessible, cost-effective, and generally free of conflicts of interest. FACA identifies the General Services Administration as the body responsible for ensuring that all advisory committees comply with each provision, including oversight on conflicts of interest. For voting committee members designated as special government employees, this means regular screenings for incongruent biases and adhering to personal financial interest laws defined by the Office of Government Ethics.

Federal agencies use the FACA database to monitor advisory committee developments and provide timely information to Congress and the public about FAC activities. Today, the database indicates there are more than 900 active advisory committees spread across 50 federal agencies, with about one in four chartered with HHS. Last year, the Centers for Disease Control and Prevention (CDC) and the Food and Drug Administration (FDA) alone held more than 50 meetings to address issues ranging from occupational radiation exposure to vaccine approval. Tracking the tangible impact of FAC influence in general is difficult; however, one study found that the FDA aligned with its advisory committees in 88 percent of drug approval cases over a 10-year period.

Given this robust regulatory framework, the administration’s recent changes to the composition and process of several key advisory committees are difficult to reconcile with long-standing norms. Even if some measures stem from legitimate concerns about conflicts of interest and good intentions of reform, the approach to resolving these issues should continue to be weighed against the risk of losing highly specialized expertise to inform national policy.

Recent Changes to Health FACs

The Trump Administration has made eliminating conflicts of interest in federal health agencies a stated priority. In a May 2025 executive order titled “Restoring Gold Standard Science,” the president outlined plans to reform scientific integrity, agency transparency, and mitigating the influence of special interests. Although the administration’s guidance closely reflects both the language and principles already supported by FACA, agency officials have moved swiftly to modify advisory committee roles. Below are examples of recent changes to advisory committees at both the CDC and FDA, respectively.

Advisory Committee on Immunization Practices (ACIP)

In early June, all 17 voting panelists on the CDC’s Advisory Committee on Immunization Practices (ACIP) were dismissed. The HHS secretary justified his decision by suggesting the committee was acting as a “rubber stamp for industry profit-taking agendas.” Days later, the secretary followed up changes to ACIP by announcing that a new panel consisting of eight (later seven) new members would meet later in the month.

ACIP’s charter outlines its task to provide counsel on the appropriate use of vaccines and related agents in combating all preventable diseases. This process requires ACIP and its subcommittees to make recommendations to the CDC director on a somewhat routine basis, with careful consideration of emerging data and science. Notably, ACIP has the statutory authority to consider which vaccines are free for children of low-income families through the Vaccines for Children Program. Based on the committee’s findings, the CDC may choose whether to list the vaccine on the official adult and childhood immunization schedules. ACIP only makes its recommendations for vaccines already approved and licensed by the FDA. For that reason, the committee has supported the use of vaccines in nearly all cases, with some rare exceptions.

While enforcing conflict of interest standards are important, the administration’s actions overstepped institutional norms on oversight and may have been exaggerated. Although agency leaders do possess the authority to dismiss committee members, it has historically been the role of ethics committees to review and make decisions on potential conflicts of interest. This norm was underscored in the case of a new appointee for the reconstituted ACIP panel, who withdrew from the vetting process in June 2025 amid concerns over financial holdings.

Furthermore, according to the Centers for Medicare and Medicaid Services’ (CMS) Open Payment Records, only five out of the 17 previous ACIP panelists had any demonstrated financial transactions with the vaccine industry. This may appear harmful to agency objectives, but research on advisory committee behavior indicates that broad financial ties with the industry do not necessarily lead to unusual biases. Moreover, a recent study indicated that ACIP panels have observed declining rates of conflicts of interest over the past three decades, with the previous panel exhibiting one of the lowest rates on record.

Vaccine & Related Biological Products Advisory Committee (VRBPAC)

In late February, the FDA notified panelists on the Vaccine & Related Biological Products Advisory Committee (VRBPAC) that a meeting to discuss flu vaccine strains the next month would be canceled. The unusual, though not unprecedented, decision is especially confounding given the agency was under new leadership. No official reason for the cancellation was made public. A month later, officials at the FDA convened to make recommendations on flu vaccine strains without receiving any input from the VRBPAC panel or other external experts. More recently, the FDA has made it clear that FACs will not be necessary for reviewing data in certain biological license approval. Biohaven, a vaccine manufacturing company, claimed the FDA “determined that an advisory committee meeting is no longer needed for regulatory decision making” after one of its products missed its phase three clinical trial endpoint.

VRBPAC’s charter notes the committee’s role in advising the FDA on matters relating to the safe and effective use of vaccines and other biological products. Committee meetings, occurring around six times per year, typically involve reviewing the safety and effectiveness of at least one therapeutic drug candidate. Much like ACIP, VRBPAC, primarily made up of physicians and medical researchers, also depends on routine collaboration between expert workgroups to help reach scientific consensus, which then informs final recommendations made to the agency.

According to the same study on former ACIP panels, the presence of conflicts of interest among members of VRBPAC has also reached record lows in recent years. This would suggest that panel selection and ethics reviews have been functioning as intended by FACA, with some degree of leeway granted to technically qualified individuals through authorized waivers. Taking this into account, many public health experts have expressed worry about the FDA’s decision to exclude VRBPAC from participating in the vaccine development and approval process. In July, the Senate Committee on Appropriations brought up separate concerns about FDA transparency and conflicts of interest, suggesting that new expert panels (appointed under the new administration) were not adhering to the principles of FACA.

Impact of FACs on Consumer Choice and Public Trust

Health advisory committees have significant roles for both consumer choice and public trust. Their recommendations extend beyond just federal health policymaking; they influence patients, providers, and other health care stakeholders. Sweeping changes to FACs thus have far-reaching consequences. When federal health policies diverge from the broad consensus informed by experts, the result is a fragmented and confusing system. Over time, this lack of consensus leads to an erosion of confidence in both the federal agencies, and the broader health care infrastructure public officials are tasked with regulating. Considering these implications, it is worth exploring the potential consumer impacts of the administration’s recent changes to advisory committees that advise public health policy.

Consumer Choice and Access

Many public health experts are concerned that disruptions to advisory committees at the CDC and FDA will impact vaccine availability and affordability. These concerns were partially realized last month when the FDA altered eligibility criteria among all four approved COVID-19 shots for the 2025-2026 season. It is worth noting that even in instances when vaccines are approved for all ages and health statuses, the CDC director ultimately determines the availability of vaccines through recommendations applicable to insurers, pharmacies, and manufacturers.

As it stands, COVID-19 vaccines are the only medical device to receive changes in market availability under the new administration. The updated shots – including both mRNA and adjuvanted platforms – will only be recommended for people over the age of 65, with exceptions based on health status made for other age groups. Officials have acknowledged that this updated policy would reduce COVID-19 vaccine eligibility to just 33 percent of the total U.S. population. Given ACIP’s workgroup review of vaccine schedules earlier this year – which recommended routine COVID-19 vaccinations for most people – it is difficult to square the abrupt reversal of guidance. Full transparency and balanced participation of experts are necessary to verify the scientific and ethical basis of this recent decision.

Other common immunizations, such as those for measles, mumps, and rubella (MMR) and respiratory syncytial virus (RSV), now face similar scrutiny from within the administration. This week ACIP is scheduled to review both vaccines, with the potential for new recommendations on the horizon. Although insurers have signaled a commitment to maintaining access for certain off-label products, cost-sharing benefits cannot be fully guaranteed without CDC recommendations. Immunization coverage through federal health coverage services – including Medicaid, Medicare (apart from Part B), and the Vaccines for Children program – likewise depend on ACIP recommendations to guide which products are covered by any cost sharing.

In a counterfactual scenario where ACIP reverses its recommendations on MMR and Varicella vaccines, families could be paying hundreds if not thousands of dollars more to protect themselves from just a handful of preventable diseases. Using the MMRV vaccine as an example – selected because of the significant savings of combining MMR and varicella immunization into just two doses – consumers could be paying at least $560 for a product that would otherwise have no cost sharing through most public or private insurance. This figure almost certainly underestimates the actual total cost, as it only factors the wholesale price of the two required doses and not the added administrative fees. In fact, consumers could be paying as much as $1600 for just one dose of the MMRV vaccine. Considering this cost barrier, it is alarming to consider the possible implications of ACIP revoking its MMRV recommendations, among other highly trusted and utilized medical devices similarly under scrutiny.

Public Trust

Public confidence in federal health agencies, health care providers, and other sources of health information is declining. According to recent data from KFF, public distrust in the CDC grew by 9 percent from 66 percent in June 2023. The same poll indicates that distrust in the FDA followed a similar, though slightly less favorable, pattern over an even shorter period. Physicians have also seen an 11-percent decline in public confidence, but they are still decidedly more trusted than either the CDC or FDA. Most poll respondents indicated an awareness of the recent developments at HHS, with a large share referring to them as “major changes.” While it may not be feasible to identify all the factors behind this notable shift in public opinion, it is fair to infer that the administration has not achieved its goal of “restoring public trust” and may have unintentionally accelerated the trend of declining trust.

Critics of FACs cite “conflicts of interest” and “scientific dishonesty” as the source of declining public trust, but past studies suggest the underlying cause could be the act of introducing further doubts in the system. The Government Accountability Office alluded to this point more than two decades ago, noting that the perception of bias may be just as harmful as the real bias itself.

This principle could similarly apply to the markets federal health agencies regulate. For instance, the administration’s rhetoric about addressing corruption in the vaccine recommendation process may have led some individuals to question the need for immunization practices entirely. A KFF poll published in January marked that the share of parents who reported skipping or delaying getting their children the recommended vaccine schedule has nearly doubled since 2023, reaching 17 percent. This rise in the share of unvaccinated individuals poses a threat to herd immunity because the eradication of infectious diseases typically requires upward of 95 percent of the population to be immunized. To illustrate this point, the recent and costly outbreak of measles in Texas was likely the result of between just 5 and 13 percent of preschool children not immunized by an MMR vaccine.

Despite these trends, overall public support for routine childhood immunization has remained quite strong. Almost 80 percent of parents have expressed their endorsement of routine vaccine schedule mandates for children in public school systems. Moreover, just one in four Americans believe the administration’s new vaccine recommendations are based on science, according to a recent by Ipsos and Reuters.

The overhaul of norms, personnel, and policies at federal agencies has exacerbated the public’s distrust of health policy. From the latest polling information, it is apparent that most individuals view these changes as disruptive and inconsistent with broad expert consensus. Officials at federal health agencies should be cognizant of these widespread concerns, as each administrative or regulatory decision not only risks a further decline in public trust in health care institutions, but also jeopardizes consumer access to crucial health care.

Conclusion

The recent membership and process changes to several key health FACs have spurred concerns about the role of experts in federal policymaking and the future of public health norms. Although FACs should be protected against conflicts of interest and other concerns of bias, the administration’s approach to overhauling advisory committees oversteps long-standing federal norms and may lack sufficient justification. Caution should be exercised with these continued changes, as advisory committees play an essential role in ensuring effective policy. Significant transformations to the role and composition of FACs, particularly among health agencies, may restrict critical consumer choices. That could have serious implications for the future of U.S. health care.