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August 18, 2025
by Joanne S. Eglovitch

Study disputes claims of rampant conflicts of interest within ACIP and VRBAC

Conflicts of interest (COIs) within the Advisory Committee on Immunization Practices (ACIP) and the Vaccines and Related Biological Products Advisory Committee (VRBPAC) have significantly decreased over the past 25 years, reaching historically low levels by 2024, according to a recent research letter published in JAMA. It contradicts assertions by US Health and Human Services Secretary Robert Kennedy Jr.’s claims during his confirmation hearing that the committees are "plagued" by conflicts of interest.

In a 2000 congressional report regarding a single vaccine, Kennedy claimed that "97% of the members on [ACIP] had conflicts." ACIP operates under the authority of the Centers for Disease Control and Prevention (CDC). The concerns prompted Kennedy to dismiss all 17 members of the CDC's ACIP earlier this summer and replace them with his own appointees. (RELATED: This Week at FDA: Kennedy revamps ACIP, FDA seeks consumer advisors, MDUFA meeting scheduled, Regulatory Focus 13 June 2025).

Genevieve Kanter, from the Department of Health Policy and Management at the Sol Price School of Public Policy at the University of Southern California (USC), disputed these claims. Along with her colleagues, she analyzed the prevalence of reported conflicts of interest (COIs) among attendees at meetings of ACIP and the Food and Drug Administration's Vaccine and Related Biological Products Advisory Committee (VRBPAC) held from 2000 to 2024.
 
Financial COIs for each ACIP voting meeting were obtained from a database of CDC disclosures created by HHS. The database includes past, current, and pending relationships. ACIP members are expected to recuse themselves from discussions and votes related to any product they have a current COI.
 
The study indicated that between 2000 and 2024, ACIP and VRBPAC held 4 and 3.4 meetings per year, respectively, with the highest annual frequency occurring from 2016 to 2024.
 
The average annual prevalence of COI reported for ACIP was 13.5%. This figure declined significantly from 42.8% in 2000 to 5% in 2024. The COI prevalence for VRBPAC was 11.1% in 2000 and has consistently remained below 4% since 2010. During a ten-year period, the COI prevalence rate for VRBPAC was 0%.
 
The authors wrote that “the annual rate of decline in reported COI prevalence was statistically significant for ACIP… but was not statistically significant for VRBPAC.”
 
The most common type of conflict reported was related to research or investigator support, which accounted for 10.1% of attendees for ACIP and 1% for VRBPAC. This was followed by conflicts associated with data and safety monitoring boards, blinded endpoint reviewers, consulting, and stock or royalty ownership. The average recusal rates were 1.3% for ACIP and 7.4% for VRBPAC.
 
The authors said that although annual prevalence rates of reported COIs were high in the early 2000s -- reaching 43% for ACIP and 27% for VRBPAC -- these rates dropped significantly from 2016 to 2024. During this period, COI rates were 6.2% for ACIP and 1.9% for VRBPAC.
 
The most commonly reported COI was related to research support, reflecting members’ expertise, with conflicts that were related to personal income stemming from consulting, stock or royalties, or ownership. The rate for research support has remained less than 1% for both committees since 2016.
 
According to the authors, policy changes that introduced caps on FDA advisory committee COI rates in 2007 and increased awareness and scrutiny of COIs in agency decision-making may have contributed to the significant declines in COI rates. They concluded that "reported COI prevalence rates have declined for ACIP and VRBAC over the last 25 years and were at historically low levels through 2024."

Study
 
 
 
 
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