Immunization laws and Board of Health rules

• Health care worker influenza vaccine requirements - Board of Health rule 6 CCR 1011-1 Chap 02
• Senate Bill 13-222 - Improving Access to Childhood Immunizations
• Senate Bill 23-260 - Individual Access to Publicly Funded Vaccines
• Senate Bill 23-162 - Increase Access to Pharmacies

School-required immunization laws and Board of Health rules

• The Infant Immunization Program And Immunization Of Students Attending School - Board of Health rule 6 CCR 1009-2
• Colorado School Entry Immunization Law C.R.S. 25-4-901 et seq
• House Bill 14-1288 - Student Immunizations Prior To School Attendance
• Senate Bill 20-163 - School Entry Immunization

Changes have been made to Colorado school immunization rules

On Dec. 17, the Colorado Board of Health revised 6 Colorado Code of Regulations (CCR) 1009-2 - The Infant Immunization Program and Immunization of Students Attending School. 

These rules establish immunization requirements for students attending school, which include public, private, or parochial kindergarten, elementary, or secondary schools through 12th grade; all child care facilities licensed by the State of Colorado, including: child care centers, school-age child care centers, preschools, day camps, resident camps, day treatment centers, family child care homes, foster care homes, and Head Start programs; and higher education facilities with residence facilities. The rules cover:

• Minimum immunization requirements to attend school,  
• Exemptions processes,
• Requirements around denial of attendance,
• Required recordkeeping and reporting by certain school facilities, and
• Other related rules.

The Board of Health approved two rulemaking proposals:

• One set of changes, done on an emergency basis, is now in effect.
• A second set of changes will go into effect on Feb. 14.

Colorado Board of Health rule 6 CCR 1009-2 will soon be updated on the Secretary of State’s Code of Colorado Regulations webpage for this rule.

The changes that are now in effect include:

• The incorporation by reference of the 2025 AAP Recommended Child and Adolescent Immunization Schedule.
• The addition of Appendix A to define the immunization requirements for students attending public, private, or parochial secondary schools through grade 12 who are aged 19 through 21 years, since the AAP immunization schedule only covers children 18 years and younger.
• Updates to language throughout the document to reflect the above changes in immunization schedule references.

Key changes that are already in effect because of the passage of House Bill 25-1027 include:

• The “in process” period for a student has been extended from 14 days to 30 days. This period refers to the time between when a school directly notifies a student or their parent or guardian of immunization noncompliance to when the student will be excluded from school if updated immunization documentation is not received.
• The deadline for schools and child cares to send the Department’s Annual Parent Letter to the parent or guardian of every enrolled student has been extended from Feb. 15 to April 15. This change will be implemented in the current 2025-2026 school year. The Department’s responsibility to update and post the Annual Parent Letter by Jan. 15 remains unchanged.

Changes to immunization policy that will be implemented in the 2026-2027 school year include:

• The timing of when the adolescent dose of the tetanus, diphtheria, and pertussis (Tdap) vaccine is required will change from before a student’s first day of sixth grade to before a student’s first day of seventh grade.
• Certificates of Medical Exemption for temporary conditions will expire after the “temporary until” date has elapsed, as determined by the immunizing provider who signed the form. Schools must monitor the expiration date of any certificates of exemption. While some medical contraindications to one or more school-required vaccines are lifelong, others are temporary, such as pregnancy, recent receipt of antibody-containing blood products, or temporary use of immunosuppressive therapies.
• New language adds clarity for when college and university students who are residing in student housing should receive a dose of meningococcal vaccine (MenACWY). The added language aligns with best practice guidelines to clarify that, in order to be valid, the MenACWY vaccine needs to be given both: 1) within the last five years, and 2) on or after the student’s 16th birthday. The added language also specifies that college or university administrators may use either: 1) the student’s move-in date, or 2) the student’s first day of classes as a fixed date to determine whether the MenACWY vaccine was administered within the required time frame. 

Guidance documents, including a memo outlining the changes and a table outlining enforcement timelines for different elements, will be available here and on the Immunization requirements for school entry webpage in the coming months.

In addition, CDPHE will schedule question-and-answer sessions with child care providers, school nurses, school administrators, higher education administrators, state regulators, camp administrators, and local public health agencies in the coming year to provide support with these rule changes.

If you have additional questions or concerns about these rule changes, email cdphe_dcphr_rulemaking@state.co.us.