Perspectives
January 16, 2026 | By Richard Moore
Policy Issues
Accountable Government Healthcare

Legislature Needs to Rein in State DHS’s Authoritarian “Science”

State agencies are not legally or ethically bound to be zombies to federal guidance. But they are also not obligated to replace it with recommendations from private associations that promote their own agendas, and their own bottom lines.

Shopping for surrogate authorities

For decades, as I have written before, American public health functioned like a vertically integrated skyscraper.

Federal agencies issued guidance; state agencies fell over each other to adopt them, not just as hard-and-fast rules commandeering our daily lives, but as Gospel from the Lord above, and bureaucrats enforced them with glee, arms extended outward to the regulatory heavens.

Nobody had any problems, so long as you followed the UN-WHO/federal-state “recommendations.” “The science.” It was vertical integration with a smiley face, as George Carlin might say, because the bureaucrats at every level—international, federal, state, and local—were only looking out for you. They always had your best interests at heart.

Meanwhile, professional associations and nonprofit “experts” filled in credentialing gaps. In other words, when bureaucrats needed a professional opinion, these were the goons they handsomely paid to provide them with answers. Miraculously, these experts rarely found fault with bureaucratic positioning.

They reinforced the same assumptions, the same incentives, and, most important, the same blind spots. They did not see for you what you were not allowed to see for yourself. Obedience and compliance took us on afternoon walks if we behaved.

Oh, how the structure has imploded.

The Trump administration’s recent decision to revise the federal childhood vaccine schedule—reducing routine doses and re-centering decision-making around families and clinicians—has exposed something much deeper than a specific divergence between the state and federal governments on an important health issue. More, it shows how state health bureaucracies behave when the federal elevator in the skyscraper suddenly stops working, and how supremely powerful the parallel unelected government in our nation is.

Some states have welcomed the chance to use the stairs for a change of pace. Florida Gov. Ron DeSantis told reporters recently that the new vaccination schedule was more manageable: 

“When somebody is recommending … or coercing, what is on the back end of that? What’s the relationship between somebody in medical and big drug companies, for example? What’s the financial arrangement? And I’m telling you, there’s a seedy underbelly to all of this stuff.”

Democratic states have so far stuck to the seedy underbelly. After some panicky handwringing, they responded in a far more revealing, though not surprising, way: Progressive-led states, including Wisconsin, scrambled to find substitute authorities—most prominently the American Academy of Pediatrics (AAP)—to preserve the same top-down posture under a different banner.

That is, they are using the tentacled allies of their faltering one-world infrastructure to cling to the same ideologies as before, when their globalist parents still reigned like substitute-Shah ayatollahs. Dare we call them “bitter clingers” in an age when authentic scientific inquiry and debate are re-emerging?

Re-emerging is an understatement. Day by day, real scientists are rising up. In laboratories, in the pages of authentic journals, and, not least, in the Trump administration’s health agencies, quiet protests are being staged. Scientific ground is being retaken.

The bitter clingers should be looking for an escape route, but instead they are choosing to die on the Boot Hill of Big Pharma. There, the globalist ayatollahs couch their counterpunch as scientific prudence, but it is little more than bureaucratic self-preservation, and it misses the real question entirely: What is the proper role of a public health agency in a pluralistic, democratic society?

The answer is surely not that which seeks to delegitimize dissent, to punish and silence any voice that veers from official government policy, or to align itself with whichever expert body best preserves institutional power.

If I were to write a policy memo—and I have on this topic, many times—the answer would be to promote neutral, transparent information-sharing, make measured recommendations when necessary, offer competing scientific inquiries and conclusions, and in general make it its mission to disseminate the greatest amount of information from all corners of an issue to the greatest number of people possible.

What changed—and why it matters

Again, no surprise, but the Wisconsin Department of Health Services (DHS), along with other progressive-controlled states, didn’t get my memo, or they filed it in the circular file.

Anyway, in early January, the Centers for Disease Control (CDC) formally revised the childhood immunization schedule, cutting the number of routine doses by 54 to 58 and reorganizing recommendations into three categories: vaccines recommended for all children, vaccines for high-risk populations, and vaccines subject to shared clinical decision-making between families and clinicians.

Critically, under the policy change, every vaccine remains available for responsible adults and families to use if they choose and is still covered by insurance. No family is blocked from access. I know, the lack of coercion would curdle a Covidian vaxxer’s tofu.

What has changed is not availability but the default presumption.

The CDC formally adopted the new schedule after President Donald Trump issued a Dec. 5 memorandum directing the agency to align U.S. vaccination policy with international best practices. The federal Department of Health and Human Services (HHS) conducted what it called a “comprehensive scientific” assessment and found that the United States recommends more routine childhood vaccine doses than peer countries without achieving higher vaccination rates or greater public trust.

A number of vaccines once considered routine for all children will now emphasize both clinician and family involvement in decision-making.

“President Trump directed us to examine how other developed nations protect their children and to take action if they are doing better,” HHS secretary Robert F. Kennedy, Jr., said. “After an exhaustive review of the evidence, we are aligning the U.S. childhood vaccine schedule with international consensus while strengthening transparency and informed consent. This decision protects children, respects families, and rebuilds trust in public health.”

Not that vaccine recommendations are being dumped altogether. Far from it. Vaccines remaining recommended for all children include those for measles, mumps, rubella, polio, pertussis, tetanus, diphtheria, Haemophilus influenzae type B (Hib), pneumococcal disease, human papillomavirus (HPV), and varicella (chickenpox).

“This vaccine schedule reflects the Danish schedule except that this revised schedule adds the varicella vaccine, which is not currently on the Danish schedule,” the CDC stated in its announcement.

There have been no health catastrophes in Denmark, it should be noted. And it should also be noted that, while Denmark might recommend the fewest vaccines among peer nations, others are also below the former U.S. guidelines, which targeted 17 diseases.

“Peer developed countries recommend fewer childhood vaccinations—Denmark recommends vaccinations for just 10 diseases with serious morbidity or mortality risks; Japan recommends vaccinations for 14 diseases; and Germany recommends vaccinations for 15 diseases,” Trump stated in his December 5 memo.

Significantly, all those nations report higher trust in public health officials, and the CDC decision memo on the schedule change pointed to specific reasons for an erosion of public trust in vaccines in this country.

“Unscientific belief that vaccine-acquired immunity was superior to infection-acquired immunity combined with inaccurate CDC claims that the Covid-19 vaccine would prevent infection and transmission eroded public trust in the Covid-19 vaccine,” the memo stated. “The loss of trust in the Covid vaccines coincided with less adherence to the full CDC childhood vaccine schedule, which has resulted in lower immunization rates of well-established vaccines, such as those for measles, rubella, pertussis, and polio.”

And despite administering significantly more doses of childhood immunizations than peer nations, the memo continued, there is a significant knowledge gap due to a dearth of randomized vaccine trials and limited post-licensure infrastructure for monitoring potential adverse reactions and long-term chronic events.

Wisconsin: Not independence but substitution

Of course, Wisconsin and its public health agencies have every right to question the new federal vaccine guidelines and the reasoning behind them. That’s exactly what current administration health officials—not to mention reporters like me—have been doing for more than 15 years now.

But instead of questioning and even promoting a different point of view, while also issuing the federal guidance, the state DHS dissed the new guidance as disinformation and jumped right into bed with its old allies in the medical establishment. In particular, DHS said it would continue to follow the American Academy of Pediatrics’ (AAP) immunization schedule.

“Copying another country’s schedule without its health and social infrastructure will not produce the same health outcomes,” DHS secretary-designee Kirsten Johnson said of the HHS recommendations. “It creates chaos and confusion and risks the health of Wisconsin’s youngest and most vulnerable citizens.”

Johnson said the state’s reaffirmed guidance aligned with extensive evidence supporting the safety and effectiveness of previously recommended vaccines, as well as the recommendations of the AAP and other leading medical organizations.

DHS chief medical officer Dr. Ryan Westergaard echoed his bureaucratic boss.

“Wisconsin’s clinicians deserve guidance that relies on systematic and transparent reviews of scientific evidence,” Westergaard said. “We have not seen any new scientific evidence that would justify changes to the childhood vaccine schedule, which is widely understood to have prevented millions of infections and continues to protect the health of children in the United States.”

The declaration was clear: Wisconsin will hold the line. But let’s look closely at what was actually being said … and not said.

In those pronouncements, there was not one word about vaccine injury nor about the billions of dollars paid out by the U.S. vaccine court to compensate those injured by “safe, effective” vaccines. There was not one word about why the full childhood schedule has never undergone inert-placebo randomized testing, not one word about the lack of long-term observational studies to better gauge vaccine benefits, risks, and outcomes.

Not one word about the ongoing failure of some vaccines to do what they promise—protect against disease—while posing threats to life and limb. Not one word about potential immunization overload. Not one word about the chemical infiltration of these pharmaceutical products, and their subsequent transfer of aluminum and other poisons into the human body. Not one word about autism. Not one word about a possible association of childhood vaccination with sudden infant death syndrome. Not one word about peer-reviewed studies that establish strong correlations with all the foregoing and the need for further investigation as well as public awareness of the potential dangers.

Not one word. Talk about a knowledge gap, especially when states and agencies insist on absolute certainty.

The reality, of course, is that, while some vaccines are supported by strong placebo-controlled randomized trials, others rely solely on correlation, comparative trials, and observational data. So there are limits to what we know, especially about cumulative and long-term effects. Policy should reflect both the strength of evidentiary claims and their limits.

Instead, DHS parrots Anthony Fauci and all the Karens of the world: “Safe and effective. Period. Discussion closed. Shut up.”

Rather than asserting independent judgment or offering a neutral promotion of information, DHS swapped one centralized authority for another, and one that is far less transparent. This is vertical integration by detour.

Authority without accountability

Which brings us to the American Academy of Pediatrics, DHS’s go-to source for the latest propaganda.

Let’s not beat around the bush. This organization is not to be trusted. It is extraordinarily rich that DHS would embrace the highly conflicted AAP with a straight face and still think it had enough dignity to attack the credibility of the HHS review.

In fact, the AAP operates with remarkably opaque conflict-of-interest practices, particularly in guideline development. In an Aug. 19 post on X, Kennedy shared a screenshot of the American Academy of Pediatrics’ webpage, which thanked its top corporate donors: Moderna, Sanofi, Merck, and Pfizer.

“These four companies make virtually every vaccine on the CDC-recommended childhood vaccine schedule,” Kennedy wrote. “AAP is angry that CDC has eliminated corporate influence in decisions over vaccine recommendations and returned CDC to gold-standard science and evidence-based medicine laser-focused on children’s health.”

Kennedy observed that AAP had released its own list of corporate-friendly vaccine recommendations, the very ones that the state DHS will now recommend for our children.

“The Trump administration believes in free speech and AAP has a right to make its case to the American people,” Kennedy said. 

“But AAP should follow the lead of HHS and disclose conflicts of interest, including its corporate entanglements and those of its journal—Pediatrics—so that Americans may ask whether the AAP’s recommendations reflect public health interest, or are, perhaps, just a pay-to-play scheme to promote commercial ambitions of AAP’s Big Pharma benefactors.”

Kennedy hits the central point: Let there be transparent and independent scientific inquiry and let it go where it may; encourage challenges to those consensus outcomes and paradigms; and promote all substantial points of view so that adults, parents, and clinicians can, in the words of HHS, share decision-making. And do it all with utmost transparency.

It is worth noting that Kennedy and those within his orbit are not the only critics of AAP. It has been well scrutinized and criticized not merely by investigative journalists but by other scientists—and in peer-reviewed publications.

According to the publication UnDark, “one author of 2018 AAP-endorsed guidelines on adolescent depression treatment has consulted for the makers of the antidepressants Zoloft and Lexapro—a detail that was disclosed in other papers he wrote around that time, but that goes unmentioned in the guidelines.”

Then, too, Michael Schulson wrote in September in UnDark, an AAP draft policy statement recommending Covid shots for many babies and some older children falsely stated there were no conflicts of interest that the authors had to disclose.

“Public records, however, show that at least nine of the 16 members of the committee responsible for those and other immunization recommendations have received payments, research funding, or perks in the form of meals, travel, or lodging from vaccine manufacturers,” Schulson wrote. “Of those, five have financial ties to companies that market Covid-19 vaccines in the U.S.”

Likewise, donors to AAP’s highly touted Friends of Children Fund read like a Who’s Who of Big Pharma and Big Food: Abbott, GeneDX, Kate Farms, Mead Johnson, CSL Seqirus. Plus the aforementioned Pfizer, Sanofi, Moderna, and Merck.

Then there’s a piece this year in BMJ by Laura Schmidt of the University of California and colleagues, in which they dissected the 2023 AAP guidelines on childhood obesity treatment. Schmidt and the other researchers found that the AAP guidelines departed significantly from those of other countries by endorsing the use of weight-loss medications for younger children, even as concerns continue to exist about their side effects, safety and costs, regulatory processes, and their potential to undermine obesity prevention.

“Amid this uncertainty, the 2023 guidelines on treatment of childhood obesity from the American Academy of Pediatrics (AAP), the leading medical society for 67,000 US pediatricians, include a recommendation to use weight loss drugs,” the researchers wrote. “The guidelines state that pediatricians ‘should offer adolescents 12 y and older with obesity [weight] loss pharmacotherapy’ and that they ‘may’ offer these drugs to children ages 8-11. Prescriptions of anti-obesity medication for children in the US rose by 38 percent in the year following publication of the AAP guidelines, according to a preprint study.”

Put bluntly, Schmidt and colleagues used one word to describe following the AAP guidelines: Caution.

“Prescribing glucagon-like peptide 1 (GLP-1) receptor agonists such as semaglutide or tirzepatide for weight loss has created vigorous scientific debate,” they wrote.

What’s more, the researchers asserted, the AAP guidelines took a much different approach than those in the UK, Sweden, and Australia: “These all recommend against prescribing weight loss medications for children under 12, barring exceptional circumstances, while specifying that orlistat (UK) and liraglutide (Sweden) may be prescribed to children aged 12 and older.”

What’s more, the researchers continued, the AAP stated that its guidelines were vetted internally for bias. And yet …

“However, we have identified financial ties to GLP-1 developers throughout the AAP and its guideline process that, combined with irregularities in guideline development methods, suggest the AAP’s childhood obesity guidelines should be interpreted with caution,” they wrote.

Still think those AAP vaccination guidelines should be swallowed whole just like DHS wants you to? This is the kind of science the AAP is peddling—money science—and this is what the Wisconsin DHS is embracing, swearing to every resident that these recommendations come from sound, independent science when nothing could be further from the truth.

The full vaccine schedule itself has never been vetted, and the experts AAP and DHS use to traffic it are riddled with conflicts of interest.

The future

State agencies are not legally or ethically bound to be zombies to federal guidance. But they are also not obligated to replace it wholesale with recommendations from private professional associations and nonprofits that promote their own agendas and ideological commitments, not to mention their own bottom lines.

A truly independent state health agency would do something radically different: present legitimate but competing recommendations side by side, explain the evidence for each, disclose uncertainties and conflicts, and let families and clinicians decide for themselves and in consultation with each other.

After all, public health institutions were as full of malarkey during the Covid years as Wisconsin DHS says the current health agencies are. Under the Biden administration, HHS and CDC repeatedly overstated what the evidence supported.

Claims that Covid vaccines would prevent infection and transmission were presented as settled science long after contrary data appeared. Natural immunity was minimized or ignored. Adverse events were dismissed as conspiracy theory. Safe social distancing was made up out of thin air, as Fauci admitted, and decades of research showing that most masks simply do not work were thrown out overnight in favor of myriad flawed studies.

State agencies had an opportunity during Covid to act as stabilizing forces. They could have contextualized the science, explained tradeoffs, acknowledged limits, and presented themselves as uncertain collaborators with the public in a time of crisis.

For the most part, they did not. They echoed federal certainty instead. They took the stage as all-knowing masters.

The bottom line is, the state legislature needs to hold DHS accountable—not for disagreeing with the Trump administration’s new vaccination schedule but for blindly following any one recommendation at all, while trying to demonize and suppress opposing points of view.

The legislature must step in and codify a process that would both assure scientific integrity in agency determinations and ensure that valid alternative scientific opinions are aired, something that did not happen during Covid despite protestations against federal absolutism by thousands of reputable scientists. It is not happening now with childhood vaccinations.

In 2021, Sen. Mary Felzkowski (R-Tomahawk) and Rep. Alex Dallman (R-Markesan) unsuccessfully introduced a bill that would have created a peer-review process for administrative rules that are based on scientific studies. As Wisconsin Manufacturers & Commerce pointed out then, current law does not provide for a peer review process for proposed state standards.

That not only removes agency decisions from legislative oversight but also from oversight by the regulated and scientific communities. Felzkowski aimed that bill mostly at protecting industry from regulations that lacked an evidence-based rationale, particularly with respect to groundwater standards.

Now, the bill should be reintroduced and enacted and expanded to include not only administrative rules but any agency standard or policy that impacts the public and is based on scientific assessment.

You know, things such as vaccination guidelines.

The second prong of any such bill would require an agency to ask for scientifically valid alternative viewpoints and to include them in the published and approved standards. This alone would assure transparency and independence from special interests.

In this case, the DHS would still be free to endorse the APA’s guidelines. But it would also have had to present the federal recommendations in equal standing, if not with its stamp of approval, along with the reasoning behind them, as well as its own conclusions and evidence.

If state agencies want credibility back, they need to have the courage to present all sides of an issue, especially those that bureaucrats do not favor. They can no longer hide behind the “recommendations” of “experts” without any more evidence than their good word.

It’s not the bureaucracy’s job to tell us what vaccinations to take. We should not let bureaucrats and ideological partisans pass themselves off as doctors who know better than real doctors. Bureaucrats may not be able to survive disagreement, but science can. In fact, it needs disagreement to live, thrive, and move forward.

And so does democracy.

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