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​Waiver Enables Medical Students to Administer COVID-19 Vaccines; Interim Limited License Requirement for GMTs Temporarily Suspended to Boost Vaccination Effort 

February 5, 2021; Revised 04/13/2021

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.

In addition, the Governor approved the Department's request to suspend certain provisions that will increase the ability of Graduate Medical Trainees (GMTs) under the State Board of Medicine and State Board of Osteopathic Medicine to more fully participate in the vaccination effort. While licensed GMTs are able to practice medicine (including the administration of COVID-19 vaccinations) in Pennsylvania, a GMT license is limited in terms of location. Generally, a GMT license holder may only practice at the medical training facility to which the GMT is assigned.

However, once they have obtained their GMT license, graduate medical trainees do have the option to obtain an interim limited license (sometimes referred to as a "moonlighting" license). This "interim limited license" allows GMT licensees to practice outside of their assigned medical training facility for up to 24 months. Pursuant to the temporary suspensions granted by the Governor, and solely for the purpose of administering COVID-19 vaccinations at various locations throughout the Commonwealth, GMT licensees may do so outside of their assigned medical training facility without having to apply for, or be granted, an interim limited license. Suspension of the requirements for an interim limited license to administer COVID-19 vaccines shall last for the duration of the Governor's disaster emergency declaration plus an additional 90 days thereafter, unless terminated sooner.