February 2026 Compliance Recap

From our partners at UBA

Compliance Recap | February 2026

New Childhood Vaccination Guidelines and Employer Impact

In early January 2026, the U.S. Department of Health and Human Services (HHS) and the Centers for Disease Control (CDC) released major updates to the childhood immunization schedule, marking one of the most significant changes in decades. While the science behind vaccination remains unchanged, the way certain vaccines are categorized and discussed has shifted, creating new considerations for employers and their health plans.

The updated schedule reduces the number of vaccines that are universally recommended for all children from birth through age 18. Core vaccines—such as those for measles, mumps, rubella, polio, whooping cough, and chickenpox—remain universally recommended. Other vaccines, including influenza, COVID-19, hepatitis A and B, RSV, rotavirus, and some meningococcal vaccines, are now recommended based on either a child’s risk factors or shared clinical decision-making between families and healthcare providers.

Importantly, access has not changed. All recommended vaccines remain available and are generally covered at no cost under ACA-compliant health plans and federal programs like Medicaid and Vaccines for Children. Families should still work directly with pediatric providers to determine the appropriate vaccines for each child.

Employer Considerations

For employers, these updates are less about changes in coverage and more about communication. Under the ACA, most group health plans must continue to cover CDC-recommended vaccines without cost-sharing. However, employees may be confused by the shift away from “universal” recommendations and may question whether certain vaccines are still covered.

To prepare, employers should

• Review plan documents
• Confirm carrier and TPA guidance
• Update benefits materials to clearly explain what has changed and what has not

QUESTION OF THE MONTH

Q: If an employee loses ACA subsidies, and premiums increase significantly as a result, would that be considered a qualifying life event, allowing them to drop coverage mid-year?

A: Unfortunately, this is a very common question this year. Increased costs on the Marketplace due to the loss of ACA subsidies is not a qualifying life event entitling an employee to enroll in his or her employer’s plan mid-year. The employee will need to wait until open enrollment (or a different qualifying life event).

Answers to the Question of the Week are provided by Kutak Rock LLP. Kutak Rock provides general compliance guidance through the UBA Compliance Help Desk, which does not constitute legal advice or create an attorney-client relationship. Please consult your legal advisor for specific legal advice.

This information has been prepared for UBA by Fisher & Phillips LLP. It is general information and provided for educational purposes only. It is not intended to provide legal advice. You should not act on this information without consulting legal counsel or other knowledgeable advisors.
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