March 22, 2021
Various measures have been taken to boost the number of health care professionals available to administer COVID-19 vaccines. This includes a Declaration made by the former U.S. Acting Secretary of HHS on March 10, 2020, under the Public Readiness and Emergency Preparedness Act for Medical Countermeasures Against COVID-19 (PREP Act). That Declaration has since been amended several times.
The current Acting HHS Secretary anticipates that significantly more vaccines will be available to the public in spring and summer 2021 and wants to ensure that states have the greatest flexibility in mobilizing the workforce necessary to engage in what he describes as “the largest vaccination effort in our nation’s history.” As a result, an Amendment to the PREP Act Declaration was issued on March 12, 2021.
The primary purpose of this Amendment was to add additional categories of “qualified persons” covered under the PREP Act to expand the pool of trained professionals available to administer vaccines.
The Amendment identifies several types of actively licensed practitioners, recently retired professionals, and students in health care training programs, who − subject to appropriate training, supervision and certain other specified requirements − may participate in COVID-19 vaccination programs.
In Pennsylvania, this adds a number of professions that would not otherwise be able to administer COVID vaccines, including the following under the State Board of Medicine, the State Board of Osteopathic Medicine, the State Board of Dentistry, the State Board of Podiatry, and the State Board of Veterinary Medicine:
- Certified Nurse Midwives
- Dental students
- Optometry students
- Physician Assistants
- Physician Assistant students
- Podiatry students
- Respiratory Therapists
- Respiratory Therapy students
- Veterinary students
To administer COVID-19 vaccines and be covered as “qualified persons” under the COVID-19 PREP Act Declaration, those listed above must meet the following training, supervision, and other requirements:
- The vaccine must be authorized, approved, or licensed by the Food and Drug Administration (FDA).
- Vaccination must be ordered and administered according to the COVID-19 vaccine recommendation(s) of the Centers for Disease Control and Prevention’s (CDC) Advisory Committee on Immunization Practices (ACIP).
- Professionals must have documentation showing that the CDC COVID−19 Vaccine Training ModulesOpens In A New Window were completed, as well as any other training required that may be required by the State Local Tribal Territory (SLTT) where the vaccine is being administered. (https://www.cdc.gov/vaccines/COVID−19/training.htmlOpens In A New Window)
- Professionals must have documentation of an observation period by a currently practicing healthcare professional experienced in administering intramuscular injections, and for whom administering intramuscular injections is in their ordinary scope of practice. The observer practitioner must confirm competency of the provider in preparation and administration of the COVID-19 vaccine(s) to be administered.
- Professionals must hold current certification in basic cardiopulmonary resuscitation (CPR). For those who are seeking their first CPR certificate, such certification cannot come entirely from an online course; there must be at least some element of hands-on training.
- Professionals must comply with recordkeeping and reporting requirements of the jurisdiction in which the vaccine is to be administered, including (a) informing the patient’s primary-care provider when available, (b) submitting the required immunization information to the state or local immunization information system (vaccine registry), (c) complying with requirements with respect to reporting adverse events, and (d) complying with requirements whereby the person administering a vaccine must review the vaccine registry or other vaccination records prior to administering a vaccine.
- Professionals 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).
For healthcare professionals and students in healthcare professions who do not traditionally find themselves in the role of administering vaccines, additional training is vital. For example, the PREP Act Declaration/Amendments imposes additional training requirements on pharmacy interns and licensed pharmacists who either have not already completed the immunization training that their licensing state requires for pharmacists to order and administer vaccines, or whose licensing state does not specify training requirements for the licensed pharmacist to order and administer vaccines.
In Pennsylvania, the following training requirements apply:
- Certified Nurse Midwives, Dentists, Physician Assistants, and Podiatrists do not need to take a 20-hour ACPE-approved vaccination training program which some licensed pharmacists are required to take.
- Dental students, Physician Assistant students, Podiatry students, Respiratory Therapists, and Respiratory Therapy students who have not yet had training in the administration of injectables, must complete the 20-hour ACPE-approved vaccination training program.
- In addition to requirements under the PREP Act, Optometrists, Veterinarians, and Veterinary students must take and complete a 20-hour ACPE-approved vaccination training program that includes hands-on injection technique and the recognition and treatment of emergency reactions to vaccines.
Any authorized individual looking to enroll as a COVID-19 provider in Pennsylvania needs to complete a provider agreement form. All information for providers, including a copy of this form, can be found on the provider section of the DOH website: https://www.health.pa.gov/topics/programs/immunizations/Pages/COVID-19-Vaccine-Providers.aspx