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​Waiver Enables Medical Students to Administer COVID-19 Vaccines 

February 5, 2021

As new COVID-19 cases soar across the Commonwealth and hospitals are stretched to capacity, Pennsylvania has initiated an unprecedented effort to administer COVID-19 vaccinations at record speed. Medical students quickly offered to step in to administer these vaccinations at locations across the Commonwealth.

The State Board of Medicine and State Board of Osteopathic Medicine regulate medical students only to the extent that they perform as "clinical clerks." The statutory definition of a  clinical clerk varies slightly between the two boards. The Medical Board requires clinical clerks to be assigned to a hospital where they provide medical services while the Osteopathic Board does not have such a requirement.

The Department requested, and the Governor approved, a waiver of the section of the Medical Practice Act (63 P.S. § 422.2, 63 P.S. § 422.11.a, and 63 P.S. § 422.11.c) to allow clinical clerks licensed under both boards to assist in administering COVID-19 vaccinations across the Commonwealth, and not just in the hospitals to which they have been assigned.

Appropriate supervisors of clinical clerks for this waiver shall include physicians and surgeons, physician assistants and nurse-midwives licensed by the State Boards of Medicine and Osteopathic Medicine; and certified registered nurse practitioners and registered nurses licensed by the State Board of Nursing.

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