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Immunization laws and Board of Health rules

School-required immunization laws and Board of Health rules

Changes to Colorado school immunization rules

On Oct. 15, the Colorado Board of Health granted the Colorado Department of Public Health and Environment’s (CDPHE) request for a rulemaking hearing for proposed changes to 6 Colorado Code of Regulations (CCR) 1009-2 - The Infant Immunization Program and Immunization of Students Attending School. Stakeholders can provide feedback before the hearing on Dec. 17, 2025.

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 full set of proposed revisions can be found at this link.

Proposed changes include:

  • Incorporating the 2025 American Academy of Pediatrics (AAP) child and adolescent immunization schedule by reference.
  • Changing the requirement for the timing of the adolescent dose of the tetanus, diphtheria, and pertussis vaccine (Tdap).
  • Adding language in the definition of an “in-process student” that clarifies that parents, guardians, or emancipated students are fulfilling the plan to be in-process (as opposed to a minor student).
  • Adding language in the definition of an “in-process student” that states that a student is also considered “in-process” if their Certificate of Medical or Nonmedical Exemption has expired and they are in the process of getting their school: (1) a new Certificate of Medical or Nonmedical Exemption, (2) an immunization record documenting that the student is up-to-date on all school-required vaccine, or (3) has a signed written plan for obtaining the remaining required immunizations, administered according to the medically recommended minimum intervals.
  • Adding an Appendix (A) for vaccine requirements for students attending public, private, or parochial secondary schools through grade twelve who are aged 19 through 21 (these are identical to the requirements from the previous stakeholder engagement).
  • Clarifying valid doses or age-appropriate MMR vaccine series for college/university students. 

Since the request for rulemaking, additional small changes have been made to the rules to clarify language. 

If you have suggestions, concerns, or questions about these proposed rule changes and wish to provide your informal feedback, you may:

  1. Use this feedback form or email cdphe_dcphr_rulemaking@state.co.us. Feedback provided this way is informal and will be reviewed by staff, but not added to the official rulemaking record. Feedback submitted this way must be received by Nov. 7, 2025 at 5 p.m. Feedback submitted directly to CDPHE staff is now closed. The other two options are still available:
  2. Email or write the Board of Health directly. All written comments and testimony are part of the public record and will be posted on the Board of Health website and made available to members of the board. Refer to the Board of Health webpage for details on due dates and instructions.
  3. Provide written testimony or speak at the Dec. 17 Board of Health rulemaking hearing to testify in favor or against the proposed rules. See the Board of Health webpage for meeting details. 

On Dec.17, 2025, the Board of Health will decide whether to approve the proposed rules. If the rules are approved, they will go into effect approximately 60 days after the meeting. Refer to the Board of Health webpage for more information about the hearings. 

If you have any concerns or questions about the process or the rules, email cdphe_dcphr_rulemaking@state.co.us.