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The New Vaccine Patchwork: State Alliances and Regulatory Shifts

By Sukrti Thonse on September 11, 2025
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In recent weeks, vaccine policy has become a flashpoint at the state level. On September 3, 2025, the governors of Oregon, California, and Washington inaugurated a West Coast Health Alliance, a regional partnership aimed at preserving scientific integrity in vaccine policy amid growing skepticism toward federal health leadership. Through this partnership, the three states will start coordinating health guidelines by aligning immunization recommendations informed by respected national medical organizations and scientific evidence-based recommendations from trusted scientists, clinicians, and other public health leaders. While each state will independently pursue strategies shaped by their unique demographics, geographics, and laws, the Alliance’s coordinated plan is intended to ensure consistency and transparency across the West Coast in determining who should receive vaccines and under what circumstances.

In subsequent developments, Hawaii announced it would join the Alliance, expanding the collaboration to four states united behind evidence-driven immunization recommendations, respecting tribal sovereignty, and acknowledging each jurisdiction’s unique regulatory needs.

By contrast, Florida has moved in the opposite direction. Florida surgeon general, Joseph Ladapo, stated on September 3 that the state plans to end all state vaccine mandates, including for students to attend schools. Ladapo said his agency would roll back mandates for a half-dozen or so vaccines under its authority but that the agency will need to work with the Florida legislature on a broader package of reforms. He did not specify which vaccine mandates his agency would do away with.

Currently, all states have vaccine requirements to attend public schools with specific exceptions that vary by state (mainly for medical and religious reasons). This move to reverse the vaccine mandate for school children, and possibly a larger group, shows a significant shift in state-level policy and signals growing divergence nationwide.

What This Means for New Jersey Providers and Health Systems

These developments highlight how states are increasingly asserting authority over vaccine policy, diverging from federal standards. While most states have historically aligned closely with CDC guidance, the current climate suggests we may see greater variability in immunization requirements, school-entry rules, and employer/healthcare provider obligations.

For New Jersey providers, this trend matters for several reasons:

  • Regulatory Drift: If states like California or Florida test new approaches, others may follow, either strengthening or loosening requirements.
  • Compliance Complexity: Multi-state providers, payors, and vendors will need to navigate inconsistent state rules.
  • Future in NJ: New Jersey could face pressure to adopt its own state-specific vaccine policies if public confidence in federal guidance erodes further.

Greenbaum’s Healthcare team is actively monitoring these state-led initiatives. We are prepared to advise physician groups, health systems, and management companies on compliance with evolving immunization requirements, the potential need to adjust policies for multi-state operations, and any state-specific rulemaking that could impact school-based, workplace, and clinical vaccination obligations.

Photo of Sukrti Thonse Sukrti Thonse

Associate, Corporate and Healthcare

Sukrti supports clients across a broad range of corporate and regulatory matters, advising at all stages of the business lifecycle with a strong concentration in healthcare and healthcare-adjacent industries. She regularly counsels physicians, medispas, multi-state provider groups, hospitals, and…

Associate, Corporate and Healthcare

Sukrti supports clients across a broad range of corporate and regulatory matters, advising at all stages of the business lifecycle with a strong concentration in healthcare and healthcare-adjacent industries. She regularly counsels physicians, medispas, multi-state provider groups, hospitals, and private equity sponsors on compliant corporate structuring, operational strategy, and growth initiatives. She provides guidance to healthcare start-ups, physician practices, and hospital systems on day-to-day operational, regulatory, and strategic matters, and assists clients in navigating complex and novel regulatory issues in highly regulated, multi-jurisdictional environments, including multi-state regulatory compliance and expansion.

In her corporate practice, Sukrti assists with the formation and capitalization of business structures and prepares key documents for fundraising, financing, and investor negotiations. She provides support on M&A transactions and in the structuring and implementation of Management Services Organization-Professional Corporation (MSO–PC) and Friendly PC models, ensuring compliance with Corporate Practice of Medicine (CPOM) doctrines, fee-splitting laws, and state ownership restrictions. Her work frequently involves advising on management services arrangements, equity structuring, rollover investments, and platform acquisitions involving physician-owned entities and private equity-backed healthcare companies.

Sukrti also has significant experience in physician and provider contracting, including drafting and negotiating employment agreements, independent contractor arrangements, professional services agreements, and compensation models (including wRVU-based structures), with careful attention to regulatory compliance and commercial reasonableness. Her practice includes coordinating regulatory due diligence and assisting with disclosure requirements, including for entities operating in FDA-regulated sectors.  She regularly structures and negotiates compensation arrangements with physicians in connection with employment and exclusive contracting arrangements, medical directorships, physician recruitment initiatives, office and equipment leases, and other key operational documents that support healthcare delivery and scalable platform growth.

She has developed particular strength in healthcare privacy and HIPAA compliance and works closely with firm partners to advise on federal and state regulatory frameworks. Sukrti regularly conducts multi-state regulatory analyses, including 50-state surveys addressing licensure, supervision, telehealth, reimbursement, and scope of practice considerations, enabling clients to expand across jurisdictions while mitigating regulatory risk.

Results may vary depending on your particular facts and legal circumstances.

Contact information:

sthonse@greenbaumlaw.com | 732.476.2480 | vCard

For more information visit the Greenbaum, Rowe, Smith & Davis LLP website.

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  • Posted in:
    Health Care and Life Sciences
  • Blog:
    Healthcare Perspectives
  • Organization:
    Greenbaum, Rowe, Smith & Davis LLP
  • Article: View Original Source

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