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Pennsylvania Pharmacists May Delegate Authority to Administer COVID-19 Vaccinations to Select Health Care Professionals in Pharmacies and Pharmacy-Run Vaccination Efforts

ISSUED 02/19/2021 - Revised 03/22/2021

The Wolf Administration has taken another step in its efforts to boost the number of health care professionals who are able to administer COVID-19 vaccines. Ensuring that there are enough authorized and trained healthcare practitioners to administer vaccinations is a critical issue, and one that is likely to become even more urgent as COVID-19 vaccines become more widely available.

Several waivers have already been implemented to provide increased flexibility to health care professionals and to suspend certain restrictions that may unduly prevent a maximized response to the pandemic generally, and the administration of COVID-19 vaccines specifically.

The current waiver relates to licensed Pennsylvania pharmacists who possess a valid, Board-issued Authorization to Administer Injectable Medications, Biologicals, and Immunizations.

Certain healthcare practitioners licensed by boards other than the State Board of Pharmacy – including LPNs, RNs, physicians, and physician assistants – have a scope of practice that includes the administration of injectable vaccines. The skills of these practitioners could be used in COVID-19 vaccination efforts in pharmacies or assisting with vaccination clinics and other events operated by licensed pharmacies. 

In addition, the federal government has taken (and will likely continue to take) various measures to boost the number of available vaccinators. One such measure arises out of 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. For example, a fifth amendment to the PREP Act was issued on January 28, 2021, to add additional categories of qualified persons authorized to administer COVID-19 vaccines in all jurisdictions where the PREP Act applies. A seventh amendment was issued on March 12, 2021, authorizing still more categories of qualified persons.

However, the Pharmacy Act and the Board's regulations only allow pharmacists to oversee (1) other fellow pharmacists and (2) pharmacy interns. Additionally, the Act and regulations prohibit pharmacists from delegating the task of immunization.

To allow pharmacists who hold an active Authorization to Administer Injectables limited delegation authority, the Department requested, and the Governor approved, a temporary suspension of the prohibition against delegation. This waiver will allow pharmacists to delegate the authority to administer COVID-19 vaccines to other licensed health care practitioners whose scope of practice includes the administration of injectable vaccines, or who have otherwise been authorized or made eligible to administer COVID-19 vaccinations by way of federal or state government action including but not limited to the PREP Act Declaration and its amendments.

This waiver 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.


Related COVID-19 vaccine waivers