COVID-19 Vaccine Administration

On January 31, 2020, the secretary of Health and Human Services (HHS), one of the agencies leading the federal government’s response to the COVID-19 pandemic, declared a public health emergency for the United States due to the 2019 novel coronavirus disease (COVID-19). Since then, various measures have been taken to help ensure the safety of the public. On March 12, 2021, the Public Readiness and Emergency Preparedness Act for Medical Countermeasures Against COVID-19 (PREP Act) was amended with the purpose of authorizing additional healthcare professionals to be eligible to administer the COVID-19 vaccines with a condition that these personnel meet all the required criteria for training, supervision, and other expectations.

Over the years, pharmacists have been established as the most accessible healthcare professional. For that reason, there has been a huge increase in immunization rates due to the accessibility of vaccination at pharmacies across the country. The PREP Act expanded its guidance, allowing not only pharmacists, but also pharmacy staff, to order and administer COVID-19 vaccinations and tests. HHS recognized that pharmacy interns and qualified pharmacy technicians can administer the COVID-19 vaccine, but they must meet certain requirements and provide their services under the supervision of a qualified pharmacist. If a qualified pharmacy technician works in a state with licensure and/or registration requirements, then they must be licensed and/or registered in accordance with the state requirement. If a pharmacy technician is working in a state without state licensure or registration requirements, then the qualified pharmacy technician must have a Certified Pharmacy Technician (CPhT) certification from either the Pharmacy Technician Certification Board (PTCB) or National Healthcareer Association (NHA). At this time, the Pennsylvania State Board of Pharmacy does not have any regulations for pharmacy technicians or any requirements for pharmacy technicians to register or obtain certification. To fulfill the PREP Act, pharmacy technicians in Pennsylvania must have a CPhT certification from either the PTCB or NHA. Additionally, there are specific COVID-19 administration requirements that must be met to immunize under the PREP Act:

  • The vaccination is ordered by the supervising qualified pharmacist who is readily and immediately available
    • In the case of a COVID-19 vaccine, the vaccination is ordered and administered according to Advisory Committee on Immunization Practices’ (ACIP) COVID-19 vaccine recommendation(s)
    • In the case of a childhood vaccine, the vaccination is ordered and administered according to ACIP’s standard immunization schedule
  • The state-authorized pharmacy intern or qualified pharmacy technician has completed a practical training program that is approved by the Accreditation Council for Pharmacy Education (ACPE), including hands-on injection technique and the recognition and treatment of emergency reactions to vaccines
  • The state-authorized pharmacy intern or qualified pharmacy technician has a current certificate in basic CPR
  • The state-authorized pharmacy intern or qualified pharmacy technician has completed two hours of ACPE-approved, immunization-related continuing pharmacy education during the relevant state licensing period(s)
  • The supervising qualified pharmacist must comply with any applicable requirements (or conditions of use) as set forth in the CDC’s COVID-19 vaccination provider agreement and any other federal requirements that apply to the administration of COVID-19 vaccine(s)

As millions of vaccine doses are being manufactured and distributed throughout the country, more locations and qualified healthcare personnel are needed to administer those vaccines. The Pennsylvania Health Department published a list of additional “qualified personnel” who can administer the COVID-19 vaccine under the PREP Act. As of February 9, 2021, under certain regulations, the following are authorized to administer COVID-19 vaccines: pharmacist, pharmacy intern, qualified pharmacy technician, certified nurse midwives, dentists, dental students, optometrists, optometry students, physician assistants, physician assistant students, podiatrists, podiatry students, respiratory therapists, respiratory therapy students, veterinarians, veterinary students, even recently retired professionals. The list is broken down by the type of license with the PA legal authority and when they are authorized to immunize. PHSL expects that other states have similar lists of authorized personnel.

Although this expansion of services is limited until the end of the COVID-19 pandemic, the pandemic has significantly impacted the healthcare system and how it operates by allowing different health professionals to administer not only the COVID-19 vaccine but also the testing. The addition and expansion of “qualified personnel” could impact how we will handle immunization administration in the future.


Posted: May 2021

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