Tell the CDC to Reverse the HPV Vaccination Mandate for Immigrants

The Honorable William (Bill) H. Gimson, MBA
Interim Director
Centers for Disease Control and Prevention
1600 Clifton Road
Atlanta, GA 30333

RE: HPV Vaccination Mandate for Immigrant Women and Girls

Dear Mr. Gimson:

We, the undersigned, write to express our opposition to the newly-imposed requirement that female immigrants ages 11 to 26, seeking permanent residence or entry to the U.S. be immunized against the human papillomavirus (HPV).

As you know, the Advisory Committee on Immunization Practices (ACIP) recommended in 2007 that Gardasil, the only FDA approved HPV vaccine, be administered to females ages 11 to 26 in the U.S. This recommendation became an automatic requirement for prospective immigrants when the government updated its vaccination list in July 2008.

While the HPV vaccine is recommended for girls and women in the U.S., it is not currently required of U.S. citizens in any jurisdiction. We believe that all prospective immigrant women should have the same opportunity as U.S. citizens to make an informed decision about their use of the HPV vaccine, weighing both the potential costs and health benefits of this procedure.

Moreover, the high cost of the HPV vaccine creates an unfair financial barrier for immigrant women. The FDA approved regimen consists of three doses to be administered within six months, resulting in at least $360 in vaccine costs and several visits to the doctor or clinic. This is in addition to the cost of getting up to 13 other mandatory vaccinations, and application fees amounting to over $1,000.

While we share your concern for reducing the rate of cervical cancer experienced by all women, including women of color, women who identify as lesbian, bisexual or transgender, and immigrant women, we urge you to act quickly and retract your listing of HPV as a required vaccination in the revised Technical Instructions to Civil Surgeons for Vaccinations Requirements and to direct ACIP to modify their recommendation to state that the HPV vaccination should not be mandated for immigrants. We believe our focus should be on strengthening culturally-competent outreach efforts, and increasing access to preventive health care services, such as Pap smears, for all groups of women facing a disproportionate risk of cancer. We also believe that all women should have the same right to informed decision-making over whether or not they want to be vaccinated against HPV.