The Centers for Disease Control & Prevention (CDC) has provided a new definition of what constitutes “up to date” with COVID vaccination.
The previous definition expired at the end of the Calendar Year 2025 Quarter 3 reporting period on September 28. At that time, CDC had not yet endorsed COVID vaccine recommendations for the 2025/2026 respiratory virus season. Vaccine recommendations were endorsed in early October but CDC was unable to update the reporting definition and had been advising providers to report “in the way that [was] most meaningful” to them.
This directive meant that data involving classification of vaccination status of nursing home residents and healthcare personnel reported from September 29 going forward could not be standardized and was essentially meaningless.
LeadingAge addressed this issue with both CDC and the Centers for Medicare & Medicaid Services (CMS) and a new definition has now been provided.
Effective for the reporting period that began on December 29, 2025, individuals aged 65 years and older are considered “up to date” with COVID vaccination if they have received two doses of the 2025/2026 vaccine or at least one dose of the 2025/2026 vaccine in the past six months. Individuals under the age of 65 are considered up to date if they have received one dose of the 2025/2026 COVID vaccine.
This definition will remain in effect through the end of the reporting period, March 29, 2026, and CDC reminds providers that they can go back to update data that was reported during this period prior to the release of the new definition. It is unclear at this time if CDC will continue this definition for subsequent reporting periods or if a new definition will be provided for the reporting period that begins March 30 of this year.
LeadingAge will continue discussions with CDC and CMS on this matter.