HFDF Urges A Focus on the Fundamental Individual Right to Make Medical Decisions

Statement in Response to Docket HHS-OS-2026-0332 and Request for Public Comment

Health Freedom Defense Fund (HFDF), 501(c)(3) Urges A Focus on the Fundamental Individual Right to Make Medical Decisions

On August 10, 2026, the White House released a document entitled “Delivering Gold Standard Childhood Vaccine Recommendations for Americans” into the Federal Register. It came on the heels of a document and announcement from May of the same year, which stated the administration’s interest in bringing the United States’ federally recommended vaccine schedule into alignment with other developed countries, in terms of the volume of injections and the range of diseases for which they are given. Taken together, these are laudable but modest administrative steps, in terms of potentially lessening harm and deprivation of personal liberty that occur as the result of the coercive and one-size-fits-all approach to vaccination requirements in the United States.

Lessening harm and injustice through the proposed reforms to recommendations, however, is not enough. HFDF firmly states that

1) all medical interventions introduce a risk of harm, however small or great, alongside claimed benefits

and

2) no American can or should be forced to expose themselves to that risk in a coercive manner (threatening access to schooling or work).

This injustice is worsened by low standards for vaccine safety studies, which make informed consent impossible, and most egregiously, by the liability shield introduced four decades ago for manufacturers of routine childhood vaccinations. The latter not only protects companies from accountability for injury and death of children, but blatantly reduces economic incentives to improve safety of products.

These statements from the White House do not call on Congress to repeal the legislation providing this immunity from accountability, nor do they increase inspections or safety requirements for vaccine makers to provide more meaningful informed consent and safety for existing and new vaccines. They also do not lift existing emergency declarations for Covid-19 countermeasures, which are still in force providing even more protection to manufacturers of mRNA-based injections until 2030. The PREP Act declaration can be lifted by a decision by the HHS secretary alone at any time.

Rather, these documents propose to enact change by reorganizing designations in federal recommendations related to vaccination requirements in some modest and mostly positive ways. These include recommending that some injections be potentially delayed, that others be split into several injections rather than single combinations, and that some injections be subjected to “shared clinical decision-making” with health providers and parents—a minimal recognition of the rights of parents to deviate from the recommended schedule. Others, like the Hepatitis B injection, may no longer be recommended on the first day of an infant’s life. If we accept that this coercive childhood vaccination paradigm is permanently in place, then these minor changes would be far more meaningful, but HFDF does not accept that premise.

In terms of practical impact, this must be placed in a realistic context. Childhood vaccination requirements for schooling are the domain of the states under our constitutional system, and the assumption that state requirements will continue dutifully following recommendations from HHS is looking more antiquated by the day. While the reasons for this may be partisan at the moment in some states, local control over health policy is a positive development in the long term. Over a dozen states now have legislation pending or passed that increases health freedom and individual rights.  While providing information from federal agencies can be helpful in principle, it is only so when it is based on reliable data collected over long timelines, and certainly not when it serves to rebuild or strengthen an old, coercive system in practice; one that denies people school, jobs, or access to society based on their personal health choices regarding vaccines.

Regarding the specific questions in the RFI, HFDF responds with the following:

1. The categories used in Federal vaccine recommendations are not only inadequate, they are improper. The federal government should not be in the doctor’s office with patients even if “shared clinical decision-making” is a minor improvement over an entirely one-size-fits all policy. Patients alone should be making decisions for themselves and their children without government interference. There is no need or place for CDC to recommend or not recommend a vaccine. The mere act of CDC creating a recommended list, irrespective of the categorization of an individual injection, implies to parents that the listed vaccines are proven safe and that assertion is patently false.
   
2. No vaccine that has not been subjected to a genuine inert placebo-controlled study should appear on any recommended list from CDC. While CDC is not in control of the severely lacking approval process at FDA, it can refuse to recommend or in any way endorse any shot that has not been subjected to proper safety studies using true placebos, lasting many years in duration, and employing control groups containing both healthy and individuals with health challenges. Anything short of that is reckless endangerment of public health by CDC.
   
3. The default assumption by CDC, which should be stated by HHS and the White House, should be that all vaccine choices, like all medical choices, should be voluntary. There should be no need for exemptions because each and every person is best positioned to make decisions for themselves and their children.
   
4. The only way to earn and maintain public trust is to be honest about the utter lack of proper safety testing with respect to vaccines. Americans deserve to know that decades of malfeasance have led to the injury of millions of Americans and that that stops now. If HHS and CDC genuinely desire to restore public trust, breaking with decades of dishonesty must be a first step.

It is apparent that the longstanding claim that CDC and HHS were infallible in their recommendations, was never serious. Already, states are creating their own vaccination schedules in consultation with one another, unfortunately in some cases with lavishly funded industry trade groups posing as charities, like the Infectious Disease Society of America and the American Academy of Pediatrics, who receive most of their funding from pharma-sponsored events. But the overall trend toward local decision-making should be embraced rather than denied. The states have moved on, and no longer defer to Washington D.C. If CDC wants to play a meaningful role in public health, then a transparent statement regarding the true state of affairs is necessary. However, even a truthful assessment would not negate the importance, which should be protected, of states choosing their own direction.

Therefore, we propose a bolder stance for this White House. If concrete legislative change cannot be secured to protect individual rights to make our own medical decisions with legislators spending more time in recess than in Congress, statements of intent will only go so far and their impacts will be temporary. HFDF urges stronger leadership as outlined above.

In light of this, in addition to the modest rearrangements proposed, we urge a statement from the White House affirming the right and duty of individuals and parents to make their own medical decisions based on informed consent, high-quality safety data, and personal discernment. The statement should accurately clarify the risible state of vaccine science, namely that the vaccines on the existing CDC schedule have not been subjected to genuine and proper placebo-controlled studies, are often too short-term to ascertain any medium- or long-term impact, and do not include proper control groups. Secondly, the administration should work tirelessly to expose how industry funds drive state-level recommendations. That will do more to shed light on how these allegedly scientific institutions—and subsequently the states—are influenced by the pharmaceutical and medical industries.

Overall, HFDF applauds that the White House and HHS are asking for more public input in a meaningful way. The August 2026 “Gold Standard” document is important in that it addressed the concerns about the vaccination schedule and medical mandates in general. Strong and measurable majorities of Americans consider these issues to be of high importance, according to scientific polling conducted by our organization and the Brownstone Institute, implemented by John Zogby strategies. In this poll, 91% of Americans across partisan lines agreed that every individual has the right to informed consent for vaccinations and other medications, and 88% agreed on the inviolable right to refuse medical treatment, and the same percentage (87%) agreed that such a right should be protected by law. This is not a fringe issue, as the mainstream media would have its consumers believe; rather, the abuses and constitutional and moral violations of the Covid-19 response have ensured that this is an important topic for the majority of the country.

While the language of the new HHS document states explicitly that it alone will not change “enforceable law” or “substantive…rights or benefits” as a standalone document, it represents a step in the right direction in spirit. However, in this moment, HFDF urges a bolder stance that shows leadership in affirming that Americans make their own decision about their own health and that of their children, and that exposes undue industry influence over the public debate and policy-making. Even more meaningfully, we demand legislative change to remove unprecedented liability shields for vaccine manufacturers, and executive action to end the Covid-19 emergency declaration and the unconstitutional order it imposes.