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Enforcement ActionLow RiskMultistate

Oregon AG and States Sue HHS, CDC Over Vaccine Schedule Overhaul

U.S. Department of Health and Human Services and Centers for Disease Control and PreventionFebruary 24, 2026Oregon Attorney General

Summary

Health enforcement case: Oregon Attorney General Dan Rayfield, along with a coalition of states, filed a lawsuit challenging the Trump Administration's overhaul of the childhood immunization schedule. The complaint alleges that HHS Secretary RFK Jr. and CDC officials bypassed federal law, ignored scientific evidence, and endangered children by demoting key vaccines from the recommended schedule. The states seek to declare the actions unlawful and enjoin the new policy.

Remedy

The lawsuit seeks a court order to vacate the new immunization schedule and the unlawful ACIP appointments, and to enjoin their implementation.

Injunction

Contract Impact

In-house legal teams should review contracts with healthcare providers, schools, childcare facilities, and government grantees that incorporate federal immunization requirements. Key clauses to examine include: (1) compliance with CDC immunization schedules and ACIP recommendations; (2) obligations to follow federal health directives or 'current' guidelines; (3) representations regarding adherence to scientifically validated health policies; and (4) force majeure or change-in-law provisions triggered by federal policy shifts. Given the lawsuit challenges the legality of the revised schedule and ACIP's composition, contracts may need amendments to: (a) clarify which version of the immunization schedule governs (pre- or post-January 2026); (b) add language allowing for adjustments if a court invalidates the new policy; and (c) ensure references to 'CDC recommendations' or 'federal standards' are interpreted as those issued through lawful processes.

Contract Search Terms

immunization schedule compliance clauseACIP adherence requirementfederal health directive compliancevaccine mandate update provisionscientific evidence standard clauseadvisory committee procedure clausepublic health policy alignmentchildhood vaccine requirementhealth regulation adherencefederal law compliance certification

Laws Cited

Federal Advisory Committee Act

Violation Types

Entity Details

Entity

U.S. Department of Health and Human Services and Centers for Disease Control and Prevention

Also known as: Department of Health and Human Services

Industry

Other

Multistate Coalition

ArizonaCaliforniaColoradoConnecticutDelawareMaineMarylandMichiganMinnesotaNew JerseyNew MexicoRhode IslandWisconsinPennsylvania

Official Sources

Source Evidence

Entity Name
"names Health and Human Services (HHS) Secretary Robert F. Kennedy, Jr., Acting Centers for Disease Control and Prevention (CDC) Director Jay Bhattacharya, and the CDC and HHS as defendants."
Laws Cited
"ignored the scientific qualifications required by ACIP’s own charter and the Federal Advisory Committee Act (FACA)."
Summary
"Complaint alleges RFK Jr. and CDC bypassed federal law, ignored scientific evidence, and endangered children by gutting recommended childhood vaccines."

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