A document the Department of Health and Human Services sent to lawmakers to support Secretary Robert F. Kennedy Jr.’s decision to change U.S. policy on covid vaccines cites scientific studies that are unpublished or under dispute and mischaracterizes others.

One health expert called the document “willful medical disinformation” about the safety of covid vaccines for children and pregnant women.

“It is so far out of left field that I find it insulting to our members of Congress that they would actually give them something like this. Congress members are relying on these agencies to provide them with valid information, and it’s just not there,” said Mark Turrentine, a professor of obstetrics and gynecology at Baylor College of Medicine.

Kennedy, who was an anti-vaccine activist before taking a role in the Trump administration, announced May 27 that the Centers for Disease Control and Prevention would no longer recommend covid vaccines for pregnant women or healthy children, bypassing the agency’s formal process for adjusting its vaccine schedules for adults and kids. The announcement, made on the social platform X, has been met with outrage by many pediatricians and scientists.

The HHS document meant to support Kennedy’s decision, obtained by KFF Health News, was sent to members of Congress who questioned the science and process behind his move, according to one federal official who asked not to be identified because he wasn’t authorized to discuss the matter publicly.

The document has not been posted on the HHS website, though it is the first detailed explanation of Kennedy’s announcement from the agency.

Titled “Covid Recommendation FAQ,” the document distorts some legitimate studies and cites others that are disputed and unpublished, medical experts say.

HHS director of communications Andrew Nixon told KFF Health News, “There is no distortion of the studies in this document. The underlying data speaks for itself, and it raises legitimate safety concerns. HHS will not ignore that evidence or downplay it. We will follow the data and the science.”

HHS did not respond to a request to name the author of the document.

One of the studies the HHS document cites is under investigation by its publisher regarding “potential issues with the research methodology and conclusions and author conflicts of interest,” according to a link on the study’s webpage.

“This is RFK Jr.’s playbook,” said Sean O’Leary, chair of the Committee on Infectious Diseases for the American Academy of Pediatrics and an assistant professor of pediatrics at the University of Colorado School of Medicine. “Either cherry-pick from good science or take junk science to support his premise — this has been his playbook for 20 years.”

Another study cited in the document is a preprint that has not been peer-reviewed. Under the study’s title is an alert that “it reports new medical research that has yet to be evaluated and so should not be used to guide clinical practice.” Though the preprint was made available a year ago, it has not been published in a peer-reviewed journal.

The FAQ supporting Kennedy’s decision claims that “post-marketing studies” of covid vaccines have identified “serious adverse effects, such as an increased risk of myocarditis and pericarditis” — conditions in which the heart’s muscle or its covering, the pericardium, suffer inflammation.

False claims that the 2024 preprint showed myocarditis and pericarditis only in people who received a covid vaccine, and not in people infected with covid, circulated on social media. One of the study’s co-authors publicly rejected that idea, because the study did not compare outcomes between people who were vaccinated and those infected with the covid virus. The study also focused only on children and adolescents. The HHS document omitted numerous other peer-reviewed studies that have shown that the risk of myocarditis and pericarditis is greater after contracting covid for both vaccinated and non-vaccinated people than the risk of the same complications after vaccination alone.

O’Leary said that while some cases of myocarditis were reported in vaccinated adolescent boys and young men early in the covid pandemic, the rates declined after the two initial doses of covid vaccines were spaced further apart.

Now, adolescents and adults who have not been previously vaccinated receive only one shot, and myocarditis no longer shows up in the data, O’Leary said, referring to the CDC’s Vaccine Safety Datalink. “There is no increased risk at this point that we can identify,” he said.

In two instances, the HHS memo makes claims that are actively refuted by the papers it cites to back them up. Both papers support the safety and effectiveness of covid vaccines for pregnant women.

The HHS document says that another paper it cites found “an increase in placental blood clotting in pregnant mothers who took the vaccine.” But the paper doesn’t contain any reference to placental blood clots or to pregnant women.

“I’ve now read it three times. And I cannot find that anywhere,” said Turrentine, the OB-GYN professor.

If he were grading the HHS document, “I would give this an ‘F,’” Turrentine said. “This is not supported by anything and it’s not using medical evidence.”

While members of Congress who are physicians should know to check references in the paper, they may not take the time to do so, said Neil Silverman, a professor of clinical obstetrics and gynecology who directs the Infectious Diseases in Pregnancy Program at the David Geffen School of Medicine at UCLA. “They’re going to assume this is coming from a scientific agency. So they are being hoodwinked along with everyone else who has had access to this document,” Silverman said.

The offices of three Republicans in Congress who are medical doctors serving on House and Senate committees focused on health, including Sen. Bill Cassidy, R-Louisiana, did not respond to requests for comment about whether they received the memo. Emily Druckman, communications director for Rep. Kim Schrier, D-Washington, a physician serving on the House Energy and Commerce Committee, confirmed that Schrier’s office did receive a copy of the document.

“The problem is a lot of legislators and even their staffers, they don’t have the expertise to be able to pick those references apart,” O’Leary said. “But this one — I’ve seen much better anti-vaccine propaganda than this, frankly.”

C.J. Young, deputy communications director for the House Energy and Commerce Committee, confirmed that Democratic staff members of the committee received the document from HHS. In the past, he said, similar documents would help clarify the justification and scope of an administration’s policy change and could be assumed to be scientifically accurate, Young said.

“This feels like it’s breaking new ground. I don’t think that we saw this level of sloppiness or inattention to detail or lack of consideration for scientific merit under the first Trump administration,” Young said.

On June 4, Rep. Frank Pallone, D-New Jersey, and Schrier introduced a bill that would require Kennedy to adopt official vaccine decisions from the Advisory Committee on Immunization Practices, or ACIP. Young said the motivation behind the bill was Kennedy’s decision to change the covid vaccine schedule without the input of ACIP’s vaccine experts, who play a key role in setting CDC policies around vaccine schedules and access.

Kennedy announced June 9 on X that he would remove all 17 members of ACIP, citing alleged conflicts of interest he did not detail, and replace them. He announced eight replacements June 11, including people who had criticized vaccine mandates during the covid pandemic.

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