Employers face a confusing fall vaccination season

September 17, 2025

As the temperatures drop in September, employers are generally preparing to offer advice, coverage, and sometimes even shots at the workplace to protect against fall respiratory viruses. However, guidance is more complicated this year. The FDA only has approved COVID-19 vaccinations for those over 65 and those with risk factors, and the Advisory Committee on Immunization Practices (ACIP) has been reconstituted and has not yet made recommendations on COVID-19 vaccines. Pharmacies in some states have been uncertain whether their pharmacists were allowed to give vaccinations, and in other states pharmacists require provider prescriptions for COVID-19 vaccinations. As a result, many face difficulties accessing these vaccines.

Here’s what I’m thinking about employer roles during this confusing vaccine season. ACIP is scheduled to meet on Thursday and Friday, so employers should keep watch for new information.

Influenza

ACIP has again recommended influenza vaccine for all those ages 6 months and up. This is unchanged from past years, and consistent with the advice of professional societies. Influenza can lead to hospitalization and death, even of healthy people.

COVID-19

COVID-19 vaccinations have become polarizing, although there is ample evidence that these vaccinations are safe and have saved millions of lives. The most common COVID-19 vaccines, made by Moderna (Spikevax and mNexspike) and Pfizer (Comirnaty) are manufactured with mRNA. Vaccines using mRNA technology are prepared by synthesizing genetic instructions that teach cells to make a harmless viral protein to teach the body to create immunity. Traditional vaccines either insert viral particles into harmless bacteria or use killed versions of the virus. mRNA technology allows rapid vaccine design and manufacturing, which could be especially valuable in future pandemics

The FDA’s approval of the Fall 2025 COVID-19 vaccine formulations is limited to people 65 and older and people younger than 65 who have one or more underlying health conditions that put them at higher risk for severe COVID-19. The Pfizer-BioNTech vaccine is approved for ages 5 and older under those risk-condition criteria and for seniors 65+. mNexspike (Moderna) is approved for those 12 through 64 with risk factors, and 65+. Spikevax (Moderna) is also approved for those over 6 months with a risk factor. The Novavax (Nuvaxovid) vaccine is approved for people 12 and older, either 65+ or 12-64 with risk factors.

The FDA did not specifically approve COVID-19 vaccines for use in pregnancy, although pregnancy is listed as a risk factor for complications from COVID-19, and the vaccines have been associated with better maternal and newborn outcomes. The FDA did not also specifically approve COVID-19 vaccines for health care workers who do not have underlying risks, or of close contacts or caregivers of those at high risk of complications from COVID-19.

1. Respiratory Syncytial Virus (RSV)

The RSV vaccine is recommended for pregnant people at 32-36 weeks’ gestation (during RSV season, September to January) to protect infants; for all adults aged 75 or older; and for adults aged 50-74 who have risk factors for severe RSV disease. In 2025, ACIP expanded the recommendation to include adults aged 50-59 with increased risk

Implications for employers:

• Influenza:
  Employers are required to cover flu shots for all ages 6 months and older without cost sharing and should offer this coverage through both the pharmacy and medical benefits. Many employers offer “flu shot clinics” so that employees can be vaccinated at work. Making vaccination “easy” is critical. Last year, about 55% of children and 45% of adults received flu shots.

• COVID-19:
  The evidence of effectiveness and safety of COVID-19 vaccinations has not changed since last fall. Many health plans will continue to cover these, and employers are not required to change their coverage policies. Many health plan members, though, might have difficulty gaining access to these vaccinations. Employers can communicate their continued coverage of these vaccines to their members. Last year, about 23% of adults received a COVID-19 vaccination.

• RSV: Employers are required to cover RSV vaccination for pregnant women and those over age 65 and those over age 50 with risk factors, consistent with the ACIP guidelines. Many carriers will provide coverage regardless of risk factors, as determining risk factors at the pharmacy is logistically difficult. Currently, there is no recommendation for booster shots to protect against RSV. As of last November, about one-third (32%) of those ages 60 and over with a risk factor had received an RSV vaccination.

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Views expressed in Employer Coverage are purely my own.

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