Getting Ahead of the COVID-19 Vaccine

July 15, 2020|4:20 p.m.| ASTHO Staff

Scientists are working quickly to develop a safe and effective vaccine to provide immunity to COVID-19. Once a vaccine is approved, it will likely be imperative for states to authorize as many health care professionals to administer it, since the demand is expected to be extremely high. In addition, legislation authorizing alternative providers within the immunization neighborhood (e.g., pharmacies, schools, workplace, and other clinical sites) can expand the places where vaccines are available and increase access to vaccination among vulnerable populations. By recognizing that not every person is reliably linked to a healthcare provider, these policies can allow for timely and consistent immunization services.

Even before the COVID-19 pandemic, state policymakers have been expanding the types of providers permitted to vaccinate adults, children, and adolescents for specific immunization schedules. One way to do that is by authorizing pharmacists (and in certain instances, pharmacy interns) to administer vaccines to patients. With expanded administration, states are also considering and enacting legislation to improve reporting and training among pharmacists. Below is an overview of state legislative activity expanding the authority to administer the vaccine to pharmacists and pharmacy interns.

West Virginia enacted a bill instructing the board of health to propose rules--for legislative approval—that would require pharmacists to complete a board-approved immunization administration course, and to report to the identified primary care physician or other licensed health care provider any immunizations administered. It also tasks the Board of Medicine and the Board of Osteopathic Medicine to develop rules permitting a licensed pharmacist or intern to administer immunizations in accordance with guidelines promulgated by CDC, and if the person is between 11-17, with written informed parental consent when presented with a prescription and there are no contraindications. Previous law only allowed pharmacists to administer the flu and HPV vaccines to children ages 11 to 17. The bill also prohibits pharmacists from delegating the authority to administer the vaccine to any other person. California is considering a bill to include FDA approved vaccines in the types of vaccines pharmacists can independently initiate and administer. Under current law, pharmacists may independently initiate and administer vaccines listed on the routine immunization schedules recommended by the federal Advisory Committee on Immunization Practices (ACIP).

Several states have specifically proposed legislation addressing the administration of the COVID-19 vaccine once developed. New York enacted companion bills (S 8182 and A 10508) authorizing licensed pharmacists to administer a vaccine for COVID-19 approved by the FDA Center for Biologics Evaluation and Research vaccine approval process. The bill adds COVID-19 to the list of diseases for which a licensed physician or nurse practitioner may prescribe a patient to a licensed pharmacist for administering immunizations. New Hampshire introduced a bill that would authorize pharmacists and interns under supervision to administer a COVID-19 vaccine when one becomes available.

As authority to administer vaccines expands to pharmacists, states are also instituting additional requirements and training. A Louisiana bill (SB 296) would require pharmacists to complete appropriate training to administer flu immunizations and they must share documentation verifying completion with the board of health. The bill also allows pharmacists to administer an flu immunization to any person regardless of their age (current law restricts flu vaccine administration by pharmacists to individuals seven years of age or older).

Vaccination is one of the most cost-effective means of public health promotion and disease prevention. Increasing access to vaccines by expanding the institutions and providers authorized to administer them-- which may help to maintain or even increase coverage rates especially among vulnerable populations-- requires cross-sector partnerships, resources, surveillance, and enforcement. State and territorial health agencies are well positioned to utilize their expertise, staff, funding, and partnerships to educate and pursue appropriate policies that will increase or maintain vaccine coverage rates. This will also be important when a COVID-19 vaccine is approved. As the authority to administer the vaccine expands to pharmacists, it is possible that the vaccine will be distributed directly to pharmacies, and it will be imperative that guidelines regarding prioritization and reporting be developed for pharmacists immunizing patients. ASTHO will continue to monitor state legislative efforts to ensure adequate vaccination coverage.


Leah Silva, JD, is the director of state health policy at ASTHO.