Federal passage of the HI TECH Act in 2009 encourages use of Electronic Health Records, which now includes submission of Immunization Information Systems (IIS ) records. IIS were developed to improve health care quality and reduce infectious diseases, health disparities, and costs. These advantages are available to all IIS users, which may include public and/or private payers. Laws that govern IIS data exchange are developed at the state-level, and may interact with federal policies, and impact utility for all those with a stake in maintaining appropriate immunization levels. This study examines IIS and immunization records laws in 56 Grantees (50 states, five cities and Washington D.C. that receive public health funds) that specify payer information exchange. Of the 56 Grantees, 31 (55.4 percent) have payer exchange provisions (private or public), 20 of which allow direct access by payers for quality assurance, reimbursement, or evaluation purposes. The laws vary by type of exchange and allowable purpose for exchange. HI PAA is applicable when grantee law does not specify exchange. IIS can be used to facilitate measurement and immunization program evaluation, including for public and private payers. All stakeholders, including payers, should be involved in the policy making process, to improve efficiencies intended by IIS and furthered in the HI TECH Act.