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Waiver Issued by Gov. Wolf Regarding Role of Pharmacists in COVID-19 Vaccination Rollout

Last Updated: Jan 14, 2021

Gov. Wolf has approved a waiver, requested by the Pennsylvania Department of State (DOS), that temporally suspends the requirement that pharmacist administration of injectable medications, biologicals and immunizations be done only under either an order or written protocol.

Access the full waiver here.

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, they can administer any immunization, including COVID-19 vaccinations, to persons who are 18 years of age or older.

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. Subsequent federal guidance indicated that the Declaration preempts any state or local law that prohibits qualifying pharmacists from ordering and administering COVID-19 vaccines.

DOS states that the purpose of this latest waiver by Gov. Wolf 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.

Note that this waiver only applies to the order and protocol provisions of 49 Pa. Code § 27.404 and does not apply to only other statutory or regulatory requirements regarding pharmacist administration of vaccinations such as necessary recordkeeping and notification.

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