This July, the U.S. Citizenship and Immigration Services (USCIS) announced new requirements, including five new vaccinations for individuals seeking adjustment of immigration status. One of these vaccinations is Gardasil, the human papillomavirus (HPV) vaccine. Gardasil, manufactured by Merck, is the only HPV vaccine in the U.S.--also the most expensive vaccine on the market and the only vaccine to be approved for use in only one sex. The CDC's Advisory Committee on Immunization Practices (ACIP) is the only federal body that makes recommendations about immunizations; the committee's recommendations serve as the template that USCIS uses to determine immunization requirements for immigration procedures. These new requirements put increased barriers and additional burdens on women's access to adjustment of immigration status and applications for visas to enter the U.S. and stoke the already reverberating anxieties among communities of color about the HPV vaccine.

Most immigration applicants are currently required to undergo a medical exam by a certified "civil surgeon." These civil surgeons complete an I-693 medical examination and vaccination record. The new regulations that require the HPV vaccine apply to female applicants between the ages of 11 to 26. This is the only sex-specific vaccination requirement, putting particular burden on immigrant women applying for a visa or adjustment of status, further marginalizing a group that already has reduced access to health information and services that are affordable, accessible and culturally and linguistically competent.

According to the Census, there are approximately 17.5 million immigrant women in the United States today, 3 million of whom are undocumented, and 16 percent that live in poverty.  These women encounter obstacles to employment and health access; they also face violence and discrimination.  Immigrant rights and reproductive justice are intrinsically linked because the reproductive health of immigrant women is profoundly affected by immigration policy.  For women seeking adjustment of status, the USCIS' additional vaccine requirements create tremendous barriers to one of the many steps towards a pathway to citizenship.

While women of color, many who are immigrants, face disproportionate rates of cervical cancer in the U.S. (Latina women get cervical cancer at twice the rate of white women; and Vietnamese women get cervical cancer at five-times the rate of white women), efforts should be made to increase access and education about HPV and the vaccine, rather than creating further impediments to the already onerous immigration process.  The HPV vaccine is out of reach for many women with its high price tag: at a minimum, it costs $360 for the three shot regimen.  Publicly-funded access to the HPV vaccine varies state-to-state, although all low-income adolescents between the ages of 9 through 19 who are either uninsured, Medicaid-eligible, American Indian, or Alaska Native, have access to the vaccine through the federal Vaccines for Children (VFC) program. Immigrant women over the age of 19 may have greater challenges in obtaining the vaccine.  According to the Kaiser Commission on Medicaid and Uninsured and the National Council of La Raza (NCLR), between 45% and 51% of immigrants lack health coverage in the US. The lack of health insurance, coupled with the high cost of the vaccine, limits access to the vaccine for low-income immigrant women.  In addition, for immigration visa applicants abroad, the global availability and accessibility of the vaccine is questionable.

States also use the CDC's Advisory Committee on Immunization Practices recommendations when developing their own vaccine requirements for school entry. Calls for state school mandate bills for this vaccine seem to have calmed down, allowing advocates the opportunity to provide much-needed education and advocacy around HPV and cervical cancer prevention. Now this new requirement threatens that critical work. 

Instead of mandating vaccines for immigrant women's bodies, the U.S. government should increase access to health information and services that are unbiased, age-appropriate, culturally-competent and non-coercive.  Mandating a vaccine that specifically targets young non-citizen women is both sexist and xenophobic.  It will only add to the current anxieties among many communities of color about the vaccine and the government's interest in vaccinating a particular community, in this case, immigrant women.