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​New Waiver Expands the Significant Role of Pharmacists in COVID-19 Vaccination Rollout


Licensed Pennsylvania pharmacists who meet certain training and other requirements can obtain formal authorization that allows them to administer injectable medications, biologicals and immunizations. If a pharmacist has that authorization, he or she can administer any immunization, including COVID-19 vaccinations, to persons who are 18 years of age or older. These pharmacists − as well as other pharmacy vaccinators such as interns and technicians − are critical public health partners in the commonwealth's plan to increase convenient access to COVID-19 vaccines.

Historically, some pharmacies have entered into arrangements with physicians in order to receive reimbursement for flu shots and other vaccinations. Many pharmacists, however, do not have an arrangement with a physician, and even those that do have not had time to incorporate the COVID-19 vaccination into that relationship.

The U.S. Department of Health and Human Services (HHS) issued a Declaration on March 10, 2020, under the federal Public Readiness and Emergency Preparedness (PREP) Act, that allows pharmacists to order and administer COVID-19 vaccines without a physician. Although subsequent federal guidance indicates that the Declaration preempts any state or local law that prohibits qualifying pharmacists from ordering and administering COVID-19 vaccines, there appears to be continuing uncertainty about compensation to pharmacists for the provision/administration of COVID-19 vaccines.

Suspension Request Approved by the Governor

In view of the fact that many Pennsylvanians will go to their local pharmacy for vaccination, and to eliminate any confusion or uncertainty regarding qualified pharmacists' ability to enroll as providers and  to order and administer the COVID-19 vaccine, the Department of State requested, and the Governor approved, a temporary suspension of the order/written protocol requirements set forth in 49 Pa. Code § 27.404.

The purpose of this waiver is to allow a pharmacist who holds a valid Authorization to Administer Injectables to order and administer a COVID-19 vaccine without the need for an order from a licensed prescriber or a protocol approved/authorized by a physician or the medical staff of an institution; provided that any COVID-19 vaccine administration is performed in accordance with the applicable Emergency Use Authorization and the "Guidance for Licensed Pharmacists and Pharmacy Interns Regarding COVID-19 Vaccines and Immunity under the PREP Act," issued by the Secretary of HHS, as permitted by the federal PREP Act, the March 10, 2020, Declaration issued under the PREP Act, and any amendments to the March 10, 2020, Declaration.

This suspension applies solely to COVID-19 vaccines and shall last for the duration of the Governor's Disaster Emergency Declaration plus an additional 90 days thereafter, unless terminated sooner.