Trump Administration Drops Medicaid Vaccine Reporting Requirements
In a letter to state health officials last month, the Centers for medicare & Medicaid Services (CMS) announced the removal of immunization measures from the Child Core Set and Adult Core Set. These “Core Sets” measure health care performance annually, with the goal of improving the health of Medicaid and Children’s Health Insurance Program (CHIP) enrollees. dropping Medicaid vaccine reporting requirements may make it more challenging to monitor vaccination trends and the impact of recent vaccine policy changes. This policy watch describes the recent Trump administration changes to Medicaid vaccine reporting requirements and explores what impact this change may have on state Medicaid programs and enrollees.
The “Core Sets” are a set of quality measures designed to measure and improve health care quality and access. The Core Set of Children’s Health Care Quality Measures for Medicaid and CHIP, or the “Child Core Set“, includes quality measures that capture various aspects of children’s health such as behavior health care, preventive care, maternal health, acute and chronic conditions, oral health care, and experience of care as well as vaccination status. The Child Core Set was developed in 2009, voluntary annual state reporting began in 2010, and reporting became mandatory in 2024.There is also a separate set of quality measures for adult enrollees, the “Adult Core Set“.The Adult Core Set was developed in 2012, voluntary annual state reporting began in 2014, and the behavioral health measures became mandatory for states to report in 2024. To enforce compliance with mandatory measures, CMS has the authority to withhold federal Medicaid payments, though states can request a one-year exemption if they are unable to report for a specific population and measure. The Core Set data are made publicly available and are designed to measure health care access and quality for Medicaid/CHIP enrollees,
Analysis of 2022-2024 Core Set trends from the Centers for Medicare & Medicaid Services (CMS) indicates these declines. Data from CMS can help state Medicaid programs understand vaccination trends, compare their performance to other states, and inform policy decisions to improve vaccination rates. These efforts are aimed at reaching longstanding vaccination goals, such as maintaining a 90% vaccination coverage level for two doses of the measles, mumps, and rubella (MMR) vaccine among kindergarten-aged children, as outlined by the Office of Disease Prevention and Health Promotion. Healthy People 2030 sets this goal.
The future of this data collection is uncertain. It remains unclear how many states will continue to voluntarily report immunization measures. Prior to mandatory reporting requirements, the number of states reporting Child Core Set measures increased over time.
More data on Medicaid and children’s health is available from the Kaiser Family Foundation (KFF). state-level data on children’s Medicaid coverage can also be found on KFF’s website.