Letter to U.S. Senator Harry Reid (Majority Leader) requesting that he introduce or cosponsor legislation to remove the HPV vaccine from the U.S. Citizenship and Immigration Services (USCIS) requirements

December 4, 2009

The Honorable Harry Reid
Majority Leader   ­­­­­­
United States Senate
Washington, DC 20510

Dear Majority Leader Reid:

I am writing to inform you of an outrageous new requirement by the U.S. Citizenship and Immigration Services (USCIS) for women applying for visas to enter the United States or adjustment of resident status.  On behalf of the National Research Center for Women & Families, I am requesting that you introduce or cosponsor legislation to remove the Human Papilloma Virus (HPV) vaccine from the U.S. Citizenship and Immigration Services (USCIS) requirements for adjustment of status or applications for visas to enter the United States.

As of July 1, 2008, the USCIS has required women and girls seeking visas or adjustments to their resident status to obtain an expensive HPV vaccine.   This requirement is completely inappropriate for several reasons:

  1. This is the only mandated vaccine that is sex-specific and involves a virus that is spread through sexual activity.  It would protect the women against exposure from people in the U.S. who have the disease, not vice versa.  That goal is not consistent with disease testing of immigrants, since it is protecting the immigrants from those already in this country, not vice versa.
  2. The vaccine helps prevent a disease (cervical cancer) that is relatively rare in the U.S., even among women who have been exposed to the virus.
  3. The vaccine is most effective (protecting against approximately 70% of cervical cancers) for pre-teen girls and teenagers, and is much less  effective for adult women, especially those over the age of 26.
  4. The vaccine is relatively new and the risks are not yet known.  It is believed to last approximately 5 years and no booster shots are yet available.
  5. Only a small minority of girls and women in the United States have been vaccinated with the HPV vaccine.  It is therefore discriminatory to require it of girls and women entering the country.
  6. The 3 doses cost $360 at a minimum, and in some cases up to $1,000.  As previously noted, it is expected to be effective for only about 5 years.  It is a costly barrier for women navigating the immigration system, and many would be unable to continue to afford protection.

Given these facts, why would the USCIS have required these vaccines?  One can only assume that USCIS officials either did not understand the science behind the vaccines, or they were persuaded by lobbyists for the company that makes the vaccine, Merck.

Your support for legislation to remove the HPV vaccine from the USCIS requirements is needed to eliminate an unjust barrier that does not contribute to the public health of our country, and does little or nothing to benefit the health of the women involved.

The HPV vaccine was approved as a recommendation for all girls ages 11-12 by the Center for Disease Control’s Advisory Committee on Immunization Practices (ACIP) in June 2006.   It is not recommended for adult women because it is not effective for women already exposed to HPV, as most adult women are.  Although the HPV vaccine is an important tool for reproductive health, there are risks and the safety data are based on short-term studies, as are the effectiveness data. Deciding whether or not to be vaccinated for HPV should be  an informed decision by women or the parents of girls.  It should not be a federal mandate targeted at one sector of the population.

In clinical trials, Gardasil, the HPV vaccine, was tested and found effective in females less than 26 years of age for most types of HPV.  It is not effective, however, against other types of HPV that cause approximately 30% of cervical cancers.  For that reason, the vaccine needs to be combined with regular screenings for cervical cancers (Pap smears) in order to detect cervical cancer in its early stages when treatment is most effective.   Immigrant women and girls may be better off  spending their limit resources on Pap smears.

The National Research Center for Women & Families supports a standard of care that will provide girls and women-including immigrants-with the best possible options to prevent cervical cancer.  The USCIS HPV vaccine mandate fails to do that.   We strongly urge you to support actions to withdraw the HPV vaccine from the USCIS requirements.   Please feel free to contact me or our Government Relations Manager Paul Brown if you have any questions.


Diana Zuckerman, PhD