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Licensees Authorized to Administer Vaccines in California  

​Authorizing Statutes & Regulations
​Conditions for Immunizing
​Physician and Surgeon
(MD and DO)
Medical Board of California

Business and Professions Code (BPC) § 2051

BPC § 2453(a) 

  • May independently initiate, prescribe, and administer

​Nurse Practitioner

(Advanced Practice Registered Nurse)

BPC § 2837.103

  • May prescribe, administer, dispense, and furnish pharmacological agents, including over-the-counter, legend, and controlled substances without 

​Physician Assistant
Physician Assistant Board

Medical Board of California

BPC § 3502

  • When immunization is delegated in writing by a supervising physician, who is available in person or by electronic communication. 

​Naturopathic Doctor

​BPC § 3640.5

  • Under standardized procedures or protocols developed by the supervising physician
​Registered Nurse
​Board of Registered Nursing

BPC § 2725(2) and (3)

  • Under supervision, or
  • Independently, using standard procedures or protocols signed by a licensed prescribing physician or nurse practitioner

​Licensed Vocational Nurse

​BPC § 2860.5(a) 

BPC § 2860.7

  • Under the direction of a physician;
  • Upon standing orders of a supervising physician, or
  • Pursuant to written guidelines adopted by the hospital or medical group with whom the supervising physician is associated
  • Physical presence of directing or supervising physician, or an examination of the patient to be immunized thereby, are not required

​Nursing Student 

​16 California Code of Regulation (CCR) 1426.1(b)(4)(B)(2).


BPC § 2729

  • ​Nursing service must be rendered incidental to course of study at a board-approved prelicensure program or school of nursing
  • Preceptor must be present and available on the patient care unit the entire time the student is rendering nursing services 

​Medical Assistant
​BPC § 2069 (a)(1)

  • Under written order by physician, nurse practitioner, physician assistant or Certified Nurse Midwife
  • Supervisor must be onsite

BPC § 4052(a)(11)

BPC § 4052.8(a) 

16 CCR 1746.4

  • ​May independently initiate and administer ACIP vaccines to persons age at least 3 years
  • May administer immunizations to all ages pursuant to a protocol with a prescriber 

​Pharmacy Intern (licensed per BPC § 4208)

​Federal HHS Guidance(supersedes state law) 

  • ​Guidance from Federal HHS authorized State-licensed or registered pharmacy interns acting under the supervision of the qualified pharmacist to administer, to persons ages three or older COVID-19 vaccinations 

​Pharmacy Technicians

DCA Waiver DCA-20-103  
  • ​May administer to persons ages three and older under supervision and control of a supervising pharmacist who is authorized to independently initiate and administer COVID-19 vaccine
​Paramedic and EMTs

Executive Order N-25-20 

  • State and Local Emergency Medical Services Agencies have the authority to adopt optional scopes of practice (SOP).  
  • SOP expanded for California National Guard EMTs to administer COVID-19 vaccine

DCA Order Waiving Restrictions on Dentists Relating to Ordering andAdministering COVID-19 Vaccines 

  • May independently prescribe and administer COVID-19 vaccines to persons age 16 years and older
  • Must complete immunization training programs through the CDC

Students (medical or pharmacy)

  • Varies by license type, student status, supervision requirements, and school

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