As of January 1, 2026, three new CPT codes took effect for pediatric practices. CPT (Current Procedural Terminology) codes are standardized billing codes used by healthcare providers to document services and obtain insurance reimbursement.
The new codes allow providers to bill for vaccine counseling even when no vaccine is administered. Supporters argue that the codes appropriately compensate physicians for time spent discussing vaccines with hesitant patients and families.
To be clear, the concern is not that physicians are being paid for their time. Healthcare professionals deserve compensation for legitimate counseling services. The concern is what these codes represent.
Most troubling is the article’s celebration that these codes classify under-immunization as a “reportable clinical condition.” This creates a system that views vaccine declination as something requiring intervention and shifts clinical documentation from a neutral billing function into a mechanism for tracking and managing lawful medical decisions. What is presented as “population health analysis” is, in practice, the creation of standardized behavioral flags attached to deeply personal healthcare choices.
Declining a medical intervention is not a disease, diagnosis, or public health violation. Yet these codes encourage a system that increasingly treats vaccine refusal as a clinical problem requiring monitoring and intervention. TFVC will always oppose efforts to normalize the surveillance of lawful medical decisions under the banner of public health.
For more than a decade, we have watched public health officials cite “pockets” of under-immunized individuals to justify taxpayer-funded vaccine marketing campaigns. Taxpayer dollars should never be spent on advertising and propaganda campaigns for liability-free, for-profit pharmaceutical products.
These new codes may also create unexpected financial burdens for families. If insurers classify vaccine counseling as subject to deductibles, copays, or coverage limitations, patients could be billed for conversations that were never disclosed as separately billable services.
This concern is not theoretical. We have already heard from a family that received a bill for vaccine counseling only after their insurance company denied the claim. The family was never informed in advance that the discussion could be coded as a separate service or result in out-of-pocket costs.
Whether intentional or not, policies like these risk creating the perception that families are being financially penalized for exercising their right to make medical decisions for themselves or their children.
At a time when trust in healthcare institutions remains fragile, expanding systems that monitor, code, and potentially bill patients based on vaccine decisions moves us in the wrong direction.
