States Issue Their Own Guidance About COVID-19 Vaccines

Since the U.S. Food and Drug Administration (FDA) released its 2025-2026 formula approvals on Aug. 2, significantly restricting who can access the COVID-19 vaccines for the first time since their release, several states have issued their own guidance about the vaccines, as reported by a USA Today article published Sept. 15.

Under FDA’s updated approvals, only individuals over 65 and those with existing health problems are recommended to get the COVID-19 vaccine. In addition, the Centers for Disease Control and Prevention said the COVID-19 vaccines would no longer be part of its recommended immunization schedule for healthy children and pregnant women, a move that drew criticism from national medical organizations.

To bridge the gap in vaccine availability to individuals, a handful of states have expanded and protected vaccine access, issuing blanket prescriptions, executive orders and insurance coverage requirements:

California, Oregon & Washington

California, along with Oregon and Washington, announced the formation of the West Coast Health Alliance on Sept. 3 to “provide evidence-based unified recommendations” on who should receive immunizations and to ensure the public gets credible information on vaccine safety and efficacy. The three states will coordinate to release a shared, consistent immunization recommendation schedule in the coming weeks, informed by “respected national medical organizations.”

Colorado

On Sept. 3, the Colorado Department of Public Health and Environment (CDPHE) issued a public health order that essentially functions as a prescription, allowing pharmacists to provide COVID-19 vaccines to those 6 months or older without individual prescriptions beginning Sept. 5. The order also directs CDPHE to collaborate with other state agencies and offices to identify and remove barriers to vaccination, ensure state health insurance plans and Medicaid cover COVID-19 vaccines and review and revise rules to ensure pharmacies can provide COVID-19 vaccines.

Pennsylvania

Also on Sept. 3, Pennsylvania’s State Board of Pharmacy voted to allow pharmacists to administer COVID-19 vaccines based not on ACIP recommendations, but on recommendations of “other trusted authorities,” including the American College of Obstetricians and Gynecologists (ACOG), the American Academy of Pediatrics (AAP), the American Academy of Family Physicians (AAFP) and the U.S. Food & Drug Administration (FDA).

New York

New York State Governor Kathy Hochul issued an executive order Sept. 5 declaring a Statewide Disaster Emergency “due to federal actions related to vaccine access.” Executive Order 52 allows pharmacists to prescribe and administer COVID-19 vaccines to anyone 3 years or older through Oct. 5. It also allows physicians and nurse practitioners to prescribe the administration of a COVID-19 vaccine by a pharmacist.

New Mexico

On Sept. 11, the New Mexico Department of Health issued a standing order expanding access to COVID-19 vaccines, allowing healthcare providers and pharmacists to vaccinate anyone 6 months and older without requiring individual prescriptions. It also confirmed via the New Mexico Health Care Authority that Medicaid would fully cover the vaccine.

Minnesota

Minnesota Gov. Tim Walz issued an executive order Sept. 8 directing the Minnesota Department of Health to collaborate with other state agencies to “identify, review and remove barriers to vaccine access.” Executive Order 25-09 also directed the state epidemiologist to issue a standing order or protocol for protecting access to the COVID-19 vaccine no later than Sept. 24, 2025.

New Jersey

On Sept. 9, the New Jersey Department of Health issued an executive directive and standing order, with the former allowing anyone 6 months of age and older to receive a COVID-19 vaccine and the latter authorizing pharmacists to order and administer COVID-19 immunizations without an individual prescription to people aged 3 years and older. Children younger than 3 are authorized to receive the vaccine from their healthcare provider.

Connecticut

Connecticut passed several measures Sept. 10 in a joint effort between the Connecticut Department of Public Health (DPH), the Connecticut Department of Consumer Protection (DCP) and the Connecticut Insurance Department (CID). DPH released interim guidance recommending the COVID-19 vaccine based on standards put forth by the AAP, ACOG and AAFP. The DCP, meanwhile, encouraged pharcists to continue ordering and administering the vaccine as they are already allowed to. It specifies that prescribers and pharmacists may order, prescribe and administer the COVID-19 vaccine to individuals who fall outside the eligibility criteria authorized by the FDA for “off-label” useCID also issued a statement affirming that the COVID-19 vaccine must be covered by state insurance policies in line with recommendations of the professional agencies listed above and “regardless of ACIP’s position.”

Virginia

On Sept. 10, Virginia State Health Commissioner Dr. Karen Shelton signed a new statewide standing order allowing pharmacists to administer the vaccine to anyone 65 years of age and older and anyone between the ages of 18 and 64 years of age with at least one underlying medical condition without a prescription. Pharmacists in the state may administer vaccines either under the direct authorization of a medical provider or by following the Virginia Board of Pharmacy’s statewide pharmacy protocols, which are usually made in accordance with ACIP recommendations. The standing order allows pharmacists to administer the vaccine per FDA guidelines without ACIP input.

Arizona

Arizona Gov. Katie Hobbs signed an executive order Sept. 11 directing the Arizona Department of Health Services, the Arizona Board of Pharmacy and the Arizona Department of Insurance and Financial Institutions to ensure statewide access to the COVID-19 vaccine. It allows the health department to issue a standing order that serves as a prescription for pharmacists and healthcare providers to administer COVID vaccines in accordance with guidance from nationally recognized professional organizations (AAP, ACOG and AAFP). It also directs the Department of Insurance to coordinate with plan providers to cover the vaccine.

Nevada

On Sept. 5, the Nevada State Board of Pharmacy issued new guidance allowing pharmacists to administer the COVID-19 vaccine and other immunizations approved by the FDA. Previously, pharmacists in Nevada could only administer vaccinations recommended by ACIP.

Illinois

Illinois Governor JB Pritzker signed an executive order establishing the Statewide Vaccine Access Initiative Sept. 12, directing the Illinois Department of Public Health (IDPH) and other state agencies to develop consistent vaccine guidance. It directs IDPH Director Dr. Sameer Vohra to issue a standing order to enable more providers to give the vaccine after consulting with the state’s Immunization Advisory Committee, which will meet Sept. 22 to establish recommendations.