Colorado’s 2025 Proposed Vaccine Rule Changes: A Guide for Non-Vaccinating Homeschool Parents
- 3 days ago
- 5 min read
Colorado is in the process of updating its school vaccine rules, Colorado Department of Public Health and Environment (CDPHE) will vote on the proposed changes on December 17, 2025. These rules govern vaccine requirements, exemption procedures, record-keeping, and attendance policies for child care, K–12 schools, and higher education programs.
CDPHE is proposing to replace its previous schedule Advisory Committee on Immunization Practices (ACIP) references with the 2025 American Academy of Pediatrics (AAP) vaccine recommendations, add a new appendix describing requirements for students aged 19–21 who are still in high school, and revise wording throughout the document to reflect these changes. Most of the modifications are structural or administrative, clarifying timing, definitions, and how expired exemptions are handled.
The proposed changes do not eliminate exemption options. Medical and nonmedical exemptions remain available. Independent homeschool families who do not use publicly funded programs will continue to keep their own exemption statements on file without submitting anything to the state.
Parents may submit comments to the Board of Health or testify at the December 17 hearing. If adopted, some changes take effect immediately, while others begin in the 2026–2027 school year.
Different Rules for Different Homeschool Paths
For homeschool families who choose not to vaccinate, the most practical takeaway is that requirements depend entirely on the type of program a student participates in. Families enrolled in publicly funded homeschool programs—such as online public schools, district-run enrichment programs, or charter-based homeschool options—must continue following Colorado’s formal nonmedical exemption process each school year. In contrast, families operating under Colorado’s independent Home-Based Education law are not required to file exemptions with the state. Instead, they simply keep their own exemption statement as part of the student’s permanent record. The updated rule does not change this distinction. It also clarifies details about titer use, outbreak exclusions, and how schools handle expired exemptions, but these updates affect only families interfacing with public programs; independent homeschool families maintain their existing level of autonomy.
Updated Rules on Using Titers
One notable change affects the use of titers—blood tests that show antibody levels. Under the updated rule, titers are no longer accepted as an alternative to vaccination for several diseases. Families cannot use titers for Hib, Hepatitis B, pneumococcal disease, polio, or pertussis (including DTaP and Tdap). Titers remain acceptable only for measles, mumps, rubella, tetanus, diphtheria, and varicella, and all required components must show a positive result to substitute for vaccination. These restrictions apply to students enrolled in publicly funded programs; independent homeschool families who keep their own exemption statements are not required to use titers at all.
Understanding When Colorado’s Rules Apply to Your Family
While the rule changes themselves are mostly technical, they do have practical implications for how non-vaccinating homeschool families interact with Colorado’s education system. The impact depends entirely on whether a family homeschools independently or participates in any publicly funded program, even on a limited basis. To avoid confusion—and to help families understand exactly when the state’s vaccine and exemption rules apply—the following points outline the key distinctions and responsibilities every non-vaccinating homeschool parent should be aware of.
What Homeschoolers Who Don’t Vaccinate Need to Understand
The distinction between independent homeschooling and publicly funded programs is critical.
Many homeschool families do not realize that participation in any public program—even a single class, activity, sports program, or once-a-week enrichment—places their child under the same vaccine and exemption requirements as public school students.This includes:
Online public schools
Charter school homeschool programs
District-funded enrichment or electives
Co-ops or programs that receive district reimbursement
Any program where the school reports attendance or receives state funds
Independent homeschoolers remain exempt from filing forms unless they participate in something publicly funded.
Exemption renewal timelines still apply only to publicly funded settings.
If a homeschool student is in a public program:
A nonmedical exemption must be filed every school year.
Certificates expire June 30, even if filed late in the year.
Medical exemptions do not need annual renewal.
Independent homeschoolers do not renew anything; they simply keep their own exemption statement on file.
Outbreak exclusion rules still apply when students participate in public programs.
Even with an exemption:
Public schools may exclude unvaccinated students during certain outbreaks.
This is not new; it has existed for decades.
The updated rule restates it clearly.
Independent homeschoolers are not affected unless their child is enrolled in a public activity or class.
Record keeping responsibilities differ for independent homeschoolers.
Independent homeschooling families must:
Keep a permanent record for each student containing either vaccination history or a parent-written exemption statement.
Provide this record only if requested due to part-time enrollment, transfer, or in compliance with §22-33-104.5.
They do not report anything to the state.
The change in schedule authority (from ACIP references to the AAP-approved schedule) does not change the exemption categories. Homeschool families sometimes worry schedule changes alter exemption rights.They do not.
Medical exemptions stay the same.
Nonmedical exemptions stay the same.
Independent homeschool exemption statements stay the same.
The shift simply changes the reference schedule used for dose timing in public settings.
Homeschoolers entering any public school setting temporarily must comply during that time.
If a student:
Tries out a public program
Takes a class for one semester
Joins a publicly funded extracurricular activity
Enters a school for testing
…then the family must file either a medical or nonmedical exemption to participate.If they leave the program, they no longer need to file anything with the state.
College-bound homeschoolers will encounter stricter documentation.
When homeschool students enroll in college or university:
They must follow the college-level rules, regardless of prior exemption status.
Two MMR doses (or positive titers) are required unless exempt.
MenACWY is not required, but colleges must provide information and may require a signed waiver if the student declines it.
College immunization rules apply even if the student was independently homeschooled K–12.
The Online Vaccination Education Module is only required in public settings.
Independent homeschoolers:
Do not need to complete the module.
Do not need provider signatures.
Do not submit anything to CDPHE.
Only publicly funded programs require the formal Certificate of Nonmedical Exemption.
The proposed rule does not expand the list of required vaccines.
You can find the following requirements and related statues here.
The proposed rule change does not change how CDPHE collects and tracks data through The Colorado Immunization Information System (CIIS).
You can learn about CIIS here.
Read about how to opt out of CIIS here.
The rule changes are limited to:
Replacing ACIP references with the 2025 AAP schedule
Adding Appendix A for 19–21-year-olds in high school
Updating definitions (including “in-process student”)
Clarifying titer acceptance
Administrative/grammar cleanup
Revising dose timing language (Tdap)
Clarifying college/university MMR documentation
Reformatting and internal consistency updates
Read the proposed rule changes here.
Your Child, Your Decision: Informed Consent Matter
At the end of the day, no state agency—not even CDPHE—knows your child the way you do. Parents are the experts on their own children, and each family must weigh medical history, individual circumstances, and personal convictions when making decisions about vaccination. Bodily autonomy is an essential principle, and informed consent requires access to complete information—not pressure. Every vaccine licensed in the United States has a manufacturer insert available online, listing ingredients, contraindications, and potential side effects. We encourage all parents to read these inserts directly, understand the risks and benefits, and make decisions that reflect what is best for their own child. This is a private and personal choice, and families deserve the space, clarity, and respect to make it without intimidation or confusion.
Need personalized help navigating vaccine exemptions? Book a Vaccine Exemption Navigation Q&A session here.
