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IMMUNIZATION BRANCH

Licensees Authorized to Administer Vaccines in California

To navigate directly to the following types of providers, use the links below:

Physicians and Medical Students

​​Licensee*

​Authorizing Statutes & Regulations

​Conditions for Immunizing

​​Physician and Surgeon (allopathic)

Medical Board of California

BPC § 2051

  • ​May independently initiate

​Osteopathic Physician and Surgeon

Osteopathic Medical Board

of California

BPC §§ 2051 & 2453

  • ​May independently initiate

​Medical Students

Medical Board of California

BPC § 2064

Order Waiving Restrictions On Healthcare Students Administering COVID-19 Vaccines In Association With State Or Local Vaccination Efforts (dated 3/30/21)

Federal HHS Resource:
Seventh Amendment to Declaration Under the Public Readiness and Emergency Preparedness Act for Medical Countermeasures Against COVID–19

Under Standard Practice:

  • May engage in the practice of medicine, including administering vaccines, whenever and wherever prescribed as a part of their course of study.

Under DCA Waiver:

  • May administer COVID-19 vaccines in association with a state, local, or institutional vaccination effort;

  • Must be trained in administering vaccines, as determined by the student's school or training program;

  • Must complete the CDPH-prescribed immunization training programs;

  • Must have documentation of an observation period by a currently-practicing healthcare professional experienced in administering intramuscular injections, for whom administering vaccines is within their ordinary scope of practice, and who confirms competency of the student in administering the vaccine;

  • When administering vaccine, must be supervised by a currently-practicing healthcare professional who is experienced in administering intramuscular injections;

  • Must be certified in basic cardiopulmonary resuscitation;

  • Supervisor must comply with federal and state recordkeeping and reporting requirements; 

  • Must comply with applicable requirements of the CDC COVID-19 vaccine provider agreement; and,

  • Vaccine must be administered in accordance with applicable FDA emergency use authorization or license.

​Physician and Surgeon Postgraduate Training License Holders

Medical Board of California

BPC §§ 2064.5 & 2065

DCA Order Waiving Restrictions On Postgraduate Training Licensees Ordering And Administering COVID-19 Vaccines Outside Of Their Postgraduate Training Program (dated 2/11/21)

  • May practice medicine, including administering vaccines, whenever and wherever required as part of postgraduate training program.

  • May independently prescribe and administer COVID-19 vaccines outside of the postgraduate training program without program director approval if they:

  1. Comply with all federal and state recordkeeping and reporting requirements;

  2. Complete the CDPH-prescribed immunization training programs; and

  3. Administer the vaccine in accordance with any applicable FDA emergency use authorization or license.

​​Visiting Fellow Registrant

Medical Board of California

BPC §§ 2111 & 2112


  • May practice medicine, including administering vaccines, in the department or division in the medical school to which they are appointed, under the direction of the head of the department to which they are appointed, and supervised by the staff of the medical school's medical center; or,

  • May practice medicine, including administering vaccines, in the specialty program in the sponsoring hospital, under the direction and supervision of a licensed, board-certified physician and surgeon who is recognized as a clearly outstanding specialist in the field in which the foreign fellow is to be trained.

​Medical School Faculty Member Registrant 

Medical Board of California

BPC § 2113

  • ​May practice medicine, including administering vaccines, incident to and a necessary part of their duties as approved by the Board in connection with the faculty position at the medical school or academic medical center or their affiliated institutions.

​Special Faculty Permit

Medical Board of California

BPC § 2168

  • ​May practice medicine, including administering vaccines, within the medical school or academic medical center (AMC) or at affiliated institutions in which the permitholder is providing instruction as part of the medical school’s or AMC’s educational program and for which the medical school or AMC has assumed direct responsibility.

Naturopathic Doctors

​​Licensee*

​Authorizing Statutes & Regulations

​Conditions for Immunizing

​​Naturopathic Doctors

Naturopathic Medicine Committee

BPC § 3640.5

16 CCR § 4236

Order Waiving Restrictions on Naturopathic Doctors Relating to Ordering and Administering COVID-19 Vaccines
(dated 3/30/21)

Under Standard Practice:

  • Pursuant to standardized procedure or protocol, under physician and surgeon supervision, and with a furnishing number from the Naturopathic Medicine Committee.

Under DCA Waiver:

  • May independently prescribe and administer COVID-19 vaccines to persons age 16 years and older;

  • Must complete the CDPH-prescribed immunization training programs;

  • Must comply with federal and state recordkeeping and reporting requirements; and, 

  • Vaccine must be administered in accordance with any applicable FDA emergency use authorization.

Physician Assistants and Physician Assistant Students

​​Licensee*

​Authorizing Statutes & Regulations

​Conditions for Immunizing

​​Physician Assistant

Physician Assistant Board

Physician Assistant FAQs

BPC § 3502

16 CCR § 1399.540

Order Waiving Physician Assistant Supervision Requirements (dated 4/14/20)

Order Extending Three April 14, 2020, Orders Relating to Physician Assistant, Nurse Practitioner, and Nurse-Midwife Supervision By 60 Days (dated 1/26/21)

Order Waiving Restrictions On Licensed Midwives, Physician Assistants, Respiratory Care Practitioners, And Veterinarians Ordering And Administering COVID-19 Vaccines In Association With State or Local Vaccination Efforts (dated 3/30/21)

Federal HHS Resource:
Seventh Amendment to Declaration Under the Public Readiness and Emergency Preparedness Act for Medical Countermeasures Against COVID–19


Under Standard Practice:

  • The physician assistant is competent to perform;
  • The education, training, and experience have prepared the physician assistant to perform;
  • Immunization is authorized by a practice agreement; 
  • The physician assistant is supervised pursuant to the practice agreement's terms; and
  • A supervising physician is available by, at a minimum, electronic means. 

Per DCA Waiver (Order Waiving Physician Assistant Supervision Requirements): 
Criteria for performing immunization services where (1) a physician assistant provides immunization services at a site to assist with the COVID-19 response, but does not have a practice agreement in place with a physician of the site, or (2) there is no supervising physician with whom the physician assistant has a practice agreement available to supervise the physician assistant:

  • The physician assistant is competent to perform; 
  • The education, training, and experience have prepared the physician assistant to perform; and
  • A supervising physician is available by, at a minimum, electronic means.

Per DCA Waiver (Order Waiving Restrictions On Licensed Midwives, Physician Assistants, Respiratory Care Practitioners, And Veterinarians Ordering and Administering COVID-19 Vaccines In Association With State or Local Vaccination Efforts):

  • May independently prescribe and administer COVID-19 vaccines in association with a state, local, or institutional vaccination effort;
  • Must complete the CDPH-prescribed immunization training programs;
  • Must have documentation of an observation period by a currently-practicing healthcare professional experienced in administering intramuscular injections, for whom administering vaccines is within their ordinary scope of practice, and who confirms competency of the physician assistant in preparing and administering the vaccine;
  • When administering vaccine, must be supervised by a currently-practicing healthcare professional who is experienced in administering intramuscular injections;
  • Must be certified in basic cardiopulmonary resuscitation;
  • Must comply with federal and state recordkeeping and reporting requirements;
  • Must comply with applicable requirements of the CDC COVID-19 vaccine provider agreement; and,
  • Vaccine must be administered in accordance with applicable FDA emergency use authorization or license.
​Physician Assistant Students
Physician Assistant Board

Order Waiving Restrictions On Healthcare Students Administering COVID-19 Vaccines In Association With State Or Local Vaccination Efforts
(dated 3/30/21)

Federal HHS Resource:
Seventh Amendment to Declaration Under the Public Readiness and Emergency Preparedness Act for Medical Countermeasures Against COVID–19


  • May administer COVID-19 vaccines in association with a state, local, or institutional vaccination effort;
  • Must be trained in administering vaccines, as determined by the student's school or training program;
  • Must complete the CDPH-prescribed immunization training programs;
  • Must have documentation of an observation period by a currently-practicing healthcare professional experienced in administering intramuscular injections, for whom administering vaccines is within their ordinary scope of practice, and who confirms competency of the student in administering the vaccine;
  • When administering vaccine, must be supervised by a currently-practicing healthcare professional who is experienced in administering intramuscular injections;
  • Must be certified in basic cardiopulmonary resuscitation;
  • Supervisor must comply with federal and state recordkeeping and reporting requirements; 
  • Must comply with applicable requirements of the CDC COVID-19 vaccine provider agreement; and,
  • Vaccine must be administered in accordance with applicable FDA emergency use authorization or license.

Nurses and Nursing Students

​​Licensee*

​Authorizing Statutes & Regulations

​Conditions for Immunizing

Registered Nurse, Clinical Nurse Specialist, Nurse Anesthetist, Nurse Midwife, Public Health Nurse, Nurse Practitioner 

Board of Registered Nursing

BPC § 2725

  • May independently initiate.

Registered Nurse Interim Permit Holders

Board of Registered Nursing

BPC § 2732.1

16 CCR § 1414


  • Under direct supervision of a licensed registered nurse who is present and available on the patient care unit.

​Registered Nurse Temporary License Holders

Board of Registered Nursing

BPC § 2733

  • May independently initiate.

​Registered Nursing Students 
Board of Registered Nursing

BPC § 2729

Order Waiving Restrictions On Healthcare Students Administering COVID-19 Vaccines In Association With State Or Local Vaccination Efforts (dated 3/30/21)

Federal HHS Resource:
Seventh Amendment to Declaration Under the Public Readiness and Emergency Preparedness Act for Medical Countermeasures Against COVID–19


Under Standard Practice:

  • A student enrolled in a Board-approved prelicensure nursing program may provide nursing services, including immunizations, incidental to their course of nursing study.

Under DCA Waiver:

  • May administer COVID-19 vaccines in association with a state, local, or institutional vaccination effort;

  • Must be trained in administering vaccines, as determined by the student's school or training program;

  • Must complete the CDPH-prescribed immunization training programs;

  • Must have documentation of an observation period by a currently-practicing healthcare professional experienced in administering intramuscular injections, for whom administering vaccines is within their ordinary scope of practice, and who confirms competency of the student in administering the vaccine;

  • When administering vaccine, must be supervised by a currently-practicing healthcare professional who is experienced in administering intramuscular injections;

  • Must be certified in basic cardiopulmonary resuscitation;

  • Supervisor must comply with federal and state recordkeeping and reporting requirements; 

  • Must comply with applicable requirements of the CDC COVID-19 vaccine provider agreement; and,

  • Vaccine must be administered in accordance with applicable FDA emergency use authorization or license.

​Licensed Vocational Nurse

Board of Vocational Nursing and Psychiatric Technicians

BPC §§ 2860.5 & 2860.7

  • Under direction of a physician and surgeon;

  • Upon standing orders of supervising physician; or

  • Pursuant to written guidelines adopted by the hospital or medical group with whom the physician is associated.

​Licensed Vocational Nursing Students

Board of Vocational Nursing and Psychiatric Technicians

BPC § 2862

Order Waiving Restrictions On Healthcare Students Administering COVID-19 Vaccines In Association With State Or Local Vaccination Efforts
(dated 3/30/21)

Federal HHS Resource:
Seventh Amendment to Declaration Under the Public Readiness and Emergency Preparedness Act for Medical Countermeasures Against COVID–19


​Under Standard Practice:

  • When enrolled in an approved vocational nursing school and when immunization services are incidental to student course of study.

Under DCA Waiver:

  • May administer COVID-19 vaccines in association with a state, local, or institutional vaccination effort;

  • Must be trained in administering vaccines, as determined by the student's school or training program;

  • Must complete the CDPH-prescribed immunization training programs;

  • Must have documentation of an observation period by a currently-practicing healthcare professional experienced in administering intramuscular injections, for whom administering vaccines is within their ordinary scope of practice, and who confirms competency of the student in administering the vaccine;

  • When administering vaccine, must be supervised by a currently-practicing healthcare professional who is experienced in administering intramuscular injections;

  • Must be certified in basic cardiopulmonary resuscitation;

  • Supervisor must comply with federal and state recordkeeping and reporting requirements; 

  • Must comply with applicable requirements of the CDC COVID-19 vaccine provider agreement; and,

  • Vaccine must be administered in accordance with applicable FDA emergency use authorization or license. 



Midwives and Student Midwives

​​Licensee*

​Authorizing Statutes & Regulations

​Conditions for Immunizing

Licensed Midwives

Medical Board of California

Order Waiving Restrictions On Licensed Midwives, Physician Assistants, Respiratory Care Practitioners, And Veterinarians Ordering And Administering COVID-19 Vaccines In Association With State Or Local Vaccination Efforts (dated 3/30/21)

Federal HHS Resource:
Seventh Amendment to Declaration Under the Public Readiness and Emergency Preparedness Act for Medical Countermeasures Against COVID–19

  • May independently prescribe and administer COVID-19 vaccines in association with a state, local, or institutional vaccination effort;

  • Must complete the CDPH-prescribed immunization training programs;

  • Must have documentation of an observation period by a currently-practicing healthcare professional experienced in administering intramuscular injections, for whom administering vaccines is within their ordinary scope of practice, and who confirms competency of the licensed midwife in preparing and administering the vaccine;

  • When administering vaccine, must be supervised by a currently-practicing healthcare professional who is experienced in administering intramuscular injections;

  • Must be certified in basic cardiopulmonary resuscitation;

  • Must comply with federal and state recordkeeping and reporting requirements; 

  • Must comply with applicable requirements of the CDC COVID-19 vaccine provider agreement; and

  • Vaccine must be administered in accordance with applicable FDA emergency use authorization or license.

​​Licensed Midwife Student

Medical Board of California

Order Waiving Restrictions On Healthcare Students Administering COVID-19 Vaccines In Association With State Or Local Vaccination Efforts (dated 3/30/21)

Federal HHS Resource:
Seventh Amendment to Declaration Under the Public Readiness and Emergency Preparedness Act for Medical Countermeasures Against COVID–19

  • May administer COVID-19 vaccines in association with a state, local, or institutional vaccination effort;

  • Must be trained in administering vaccines, as determined by the student's school or training program;

  • Must complete the CDPH-prescribed immunization training programs;

  • Must have documentation of an observation period by a currently-practicing healthcare professional experienced in administering intramuscular injections, for whom administering vaccines is within their ordinary scope of practice, and who confirms competency of the student in administering the vaccine;

  • When administering vaccine, must be supervised by a currently-practicing healthcare professional who is experienced in administering intramuscular injections;

  • Must be certified in basic cardiopulmonary resuscitation;

  • Supervisor must comply with federal and state recordkeeping and reporting requirements; 

  • Must comply with applicable requirements of the CDC COVID-19 vaccine provider agreement; and,

  • Vaccine must be administered in accordance with applicable FDA emergency use authorization or license.

Medical Assistants

​​Licensee*

​Authorizing Statutes & Regulations

​Conditions for Immunizing

Medical Assistant

Medical Board of California

BPC § 2069

16 CCR § 1366

Order Waiving Restrictions on Medical Assistants Administering COVID-19 Vaccines (dated 3/30/21)

Under Standard Practice:
If trained to administer medication by injection, medical assistants may administer COVID-19 vaccine as follows:

  • Under written order by physician, nurse practitioner, physician assistant, or Certified Nurse Midwife

  • Licensed supervising physician, physician assistant, nurse practitioner, or certified nurse midwife, as applicable, must be onsite

Under DCA Waiver:
If trained to administer medication by injection, medical assistants may administer COVID-19 vaccine to persons age 16 years and older without a written order under the following criteria:

  • The vaccine is administered in association with a state, local, or institutional vaccination effort;

  • The medical assistant is supervised by a licensed physician, physician assistant, nurse practitioner, or certified nurse midwife, who is onsite during the administration;

  • The medical assistant has documentation of an observation period by a currently-practicing healthcare professional experienced in administering intramuscular injections, for whom administering vaccines is within their ordinary scope of practice, and who confirms competency of the medical assistant in preparing and administering the COVID-19 vaccine;

  • Must complete CDPH-prescribed immunization training programs;

  • Supervisor must comply with federal and state recordkeeping and reporting requirements; and,

  • Vaccine must be administered in accordance with any applicable FDA emergency use authorization or license.

Pharmacists, Pharmacy Interns, and Pharmacy Technicians

​​Licensee*

​Authorizing Statutes & Regulations

​Conditions for Immunizing

​Pharmacist

Board of Pharmacy

BPC §§ 4052(a)(11) & 4052.8(a)

16 CCR § 1746.4

Federal HHS Resources:
Fourth Amendment to Declaration Under the Public Readiness and Emergency Preparedness Act for Medical Countermeasures Against COVID–19

  • May independently initiate and administer ACIP vaccines to persons ages three and older.

  • May administer immunizations to all ages pursuant to a protocol with a prescriber.

  • Must be certified in basic life support and complete a CDC- or Accreditation Council for Pharmacy Education (ACPE)-endorsed immunization training program that includes a hands-on component.

​Pharmacy Intern

Board of Pharmacy

BPC § 4114

Order Waiving Restrictions On Healthcare Students Administering COVID-19 Vaccines In Association With State Or Local Vaccination Efforts (dated 3/30/21)

Federal HHS Resource:
Seventh Amendment to Declaration Under the Public Readiness and Emergency Preparedness Act for Medical Countermeasures Against COVID–19

Under Standard Practice:

  • May perform all functions of a pharmacist at the discretion of and under the direct supervision and control of a pharmacist

Under DCA Waiver:

  • May administer COVID-19 vaccines in association with a state, local, or institutional vaccination effort;

  • Must be trained in administering vaccines, as determined by the student's school or training program;

  • Must complete the CDPH-prescribed immunization training programs;

  • Must have documentation of an observation period by a currently-practicing healthcare professional experienced in administering intramuscular injections, for whom administering vaccines is within their ordinary scope of practice, and who confirms competency of the student in administering the vaccine;

  • When administering vaccine, must be supervised by a currently-practicing healthcare professional who is experienced in administering intramuscular injections;

  • Must be certified in basic cardiopulmonary resuscitation;

  • Supervisor must comply with federal and state recordkeeping and reporting requirements; 

  • Must comply with applicable requirements of the CDC COVID-19 vaccine provider agreement; and,

  • Vaccine must be administered in accordance with applicable FDA emergency use authorization or license.


Pharmacy Technician

Board of Pharmacy

Order Waiving Restrictions on Pharmacy Technicians Relating to Administering COVID-19 Vaccines (Dated 12/22/20)

Federal HHS Resources:
Fourth Amendment to Declaration Under the Public Readiness and Emergency Preparedness Act for Medical Countermeasures Against COVID–19

Guidance for PREP Act Coverage for Qualified Pharmacy Technicians and State-Authorized Pharmacy Interns for Childhood Vaccines, COVID-19 Vaccines, and COVID-19 Testing

  • May administer to persons ages three and older under direct supervision and control of a pharmacist authorized to independently initiate and administer COVID-19 vaccine.

  • Must be certified in basic cardiopulmonary resuscitation and complete six hours of ACPE-endorsed training that includes the recognition and treatment of emergency reactions to vaccines, hands-on injection technique, and an assessment of injection technique (see Pharmacy Technicians training for an example of qualifying training).

  • Vaccine must be administered according to applicable FDA emergency use authorization or license.


Emergency Medical Personnel​

​​Licensee*

​Authorizing Statutes & Regulations

​Conditions for Immunizing

​Paramedic 
(for EMT see below)

Emergency Medical Services Authority

Scope of Practice Document from EMSA, page 54

  • During a public health emergency.

  • Requires approval by the director of the local EMS agency.

EMTs

Emergency Medical Services Authority

Executive Order N-25-20

Approved COVID-19 local optional scopes of practice by county: See approved list at bottom of EMSA's COVID-19 webpage

  • Director of EMSA has authority to implement additions to local optional scopes of practice, including EMT scope of practice, when approved by the local EMS agency.

  • SOP temporarily expanded for all California National Guard EMTs.

  • SOP temporarily expanded in multiple counties (see  approved list at bottom of EMSA's COVID-19 webpage).

Dentists, Dental Students, and Dental Hygienists

​​Licensee*

​Authorizing Statutes & Regulations

​Conditions for Immunizing

​​Dentists

Dental Board of California

DCA Order Waiving Restrictions on Dentists Relating to Ordering and Administering COVID-19 Vaccines
(dated 1/27/21)

Under the Public Readiness and Emergency Preparedness Act for Medical Countermeasures Against COVID–19

  • May independently prescribe and administer COVID-19 vaccines to persons age 16 years and older.

  • Must complete the CDPH-prescribed immunization training programs.

  • Must comply with federal and state recordkeeping and reporting requirements.

  • Vaccine must be administered in accordance with any applicable FDA emergency use authorization.

Dental Students

Dental Board of California

Order Waiving Restrictions On Healthcare Students Administering COVID-19 Vaccines In Association With State Or Local Vaccination Efforts (dated 3/30/21)

Federal HHS Resource:
Seventh Amendment to Declaration Under the Public Readiness and Emergency Preparedness Act for Medical Countermeasures Against COVID–19

  • May administer COVID-19 vaccines in association with a state, local, or institutional vaccination effort;

  • Must be trained in administering vaccines, as determined by the student's school or training program;

  • Must complete the CDPH-prescribed immunization training programs;

  • Must have documentation of an observation period by a currently-practicing healthcare professional experienced in administering intramuscular injections, for whom administering vaccines is within their ordinary scope of practice, and who confirms competency of the student in administering the vaccine;

  • When administering vaccine, must be supervised by a currently-practicing healthcare professional who is experienced in administering intramuscular injections;

  • Must be certified in basic cardiopulmonary resuscitation;

  • Supervisor must comply with federal and state recordkeeping and reporting requirements; 

  • Must comply with applicable requirements of the CDC COVID-19 vaccine provider agreement; and,

  • Vaccine must be administered in accordance with applicable FDA emergency use authorization or license.

​​​Registered Dental Hygienists

Dental Hygiene Board of California

DCA Order Waiving Restrictions on Registered Dental Hygienists Relating to Administering COVID-19 Vaccines
(dated 2/11/21)

  • May administer to persons ages 16 and older under direct supervision of a dentist, or on-site supervision of a physician and surgeon, who is authorized to independently initiate and administer the subject vaccine.

  • Must complete six hours of an ACPE-endorsed training that includes the recognition and treatment of emergency reactions to vaccines, hands-on injection technique, and an assessment of injection technique (see Pharmacy Technicians training for an example of qualifying training).

  • Must also complete the CDPH-prescribed immunization training programs.

  • Supervisor must comply with federal and state recordkeeping and reporting requirements.

  • Vaccine must be administered in accordance with any applicable FDA emergency use authorization or license.

Optometrists and Optometry Students

​​Licensee*

​Authorizing Statutes & Regulations

​Conditions for Immunizing

​​Optometrists

Optometry Board of California

DCA Order Waiving Restrictions on Optometrists Relating to Ordering and Administering COVID-19 Vaccines (dated 2/11/21)

  • May independently prescribe and administer COVID-19 vaccines to persons age 16 years and older.

  • Must be certified in basic life support and complete a CDC- or ACPE-endorsed training that includes the recognition and treatment of emergency reactions to vaccines, hands-on injection technique, and clinical evaluation of indications and contraindications of vaccines (see Pharmacy-Based Immunization Delivery training for an example of qualifying training).

  • Must also complete the CDPH-prescribed immunization training programs.

  • Must comply with federal and state recordkeeping and reporting requirements.

  • Vaccine must be administered in accordance with any applicable FDA emergency use authorization or license.

​Optometry Students

Optometry Board of California

Order Waiving Restrictions On Healthcare Students Administering COVID-19 Vaccines In Association With State Or Local Vaccination Efforts (dated 3/30/21)

Federal HHS Resource:
Seventh Amendment to Declaration Under the Public Readiness and Emergency Preparedness Act for Medical Countermeasures Against COVID–19

  • May administer COVID-19 vaccines in association with a state, local, or institutional vaccination effort;

  • Must be trained in administering vaccines, as determined by the student's school or training program;

  • Must complete the CDPH-prescribed immunization training programs;

  • Must have documentation of an observation period by a currently-practicing healthcare professional experienced in administering intramuscular injections, for whom administering vaccines is within their ordinary scope of practice, and who confirms competency of the student in administering the vaccine;

  • When administering vaccine, must be supervised by a currently-practicing healthcare professional who is experienced in administering intramuscular injections;

  • Must be certified in basic cardiopulmonary resuscitation;

  • Supervisor must comply with federal and state recordkeeping and reporting requirements; 

  • Must comply with applicable requirements of the CDC COVID-19 vaccine provider agreement; and,

  • Vaccine must be administered in accordance with applicable FDA emergency use authorization or license.

Podiatrists and Podiatry Students

​​Licensee*

​Authorizing Statutes & Regulations

​Conditions for Immunizing

​Podiatrists

Podiatric Medical Board

DCA Order Waiving Restrictions on Doctors of Podiatric Medicine Relating to Ordering and Administering COVID-19 Vaccines (dated 2/11/21)

  • May independently prescribe and administer COVID-19 vaccines to persons age 16 years and older.

  • Must complete the CDPH-prescribed immunization training programs.

  • Must comply with federal and state recordkeeping and reporting requirements.

  • Vaccine must be administered in accordance with any applicable FDA emergency use authorization or license.

Podiatry Students

Podiatric Medical Board

BPC § 2476

Order Waiving Restrictions On Healthcare Students Administering COVID-19 Vaccines In Association With State Or Local Vaccination Efforts (dated 3/30/21)

Federal HHS Resource:
Seventh Amendment to Declaration Under the Public Readiness and Emergency Preparedness Act for Medical Countermeasures Against COVID–19

Under Standard Practice:

  • When performing at an approved school and under the supervision of a physician and surgeon, whenever prescribed as part of the course of study.

Under DCA Waiver:

  • May administer COVID-19 vaccines in association with a state, local, or institutional vaccination effort;

  • Must be trained in administering vaccines, as determined by the student's school or training program;

  • Must complete the CDPH-prescribed immunization training programs;

  • Must have documentation of an observation period by a currently-practicing healthcare professional experienced in administering intramuscular injections, for whom administering vaccines is within their ordinary scope of practice, and who confirms competency of the student in administering the vaccine;

  • When administering vaccine, must be supervised by a currently-practicing healthcare professional who is experienced in administering intramuscular injections;

  • Must be certified in basic cardiopulmonary resuscitation;

  • Supervisor must comply with federal and state recordkeeping and reporting requirements; 

  • Must comply with applicable requirements of the CDC COVID-19 vaccine provider agreement; and,

  • Vaccine must be administered in accordance with applicable FDA emergency use authorization or license.

​Respiratory Care Practitioners and Respiratory Care Students

​​Licensee*

​Authorizing Statutes & Regulations

​Conditions for Immunizing

​Respiratory Care Practitioner

Respiratory Care Board of California 

BPC §§ 3702 & 3703

16 CCR § 1399.364

Order Waiving Restrictions On Licensed Midwives, Physician Assistants, Respiratory Care Practitioners, And Veterinarians Ordering And Administering COVID-19 Vaccines In Association With State Or Local Vaccination Efforts (dated 3/30/21)

Federal HHS Resource:
Seventh Amendment to Declaration Under the Public Readiness and Emergency Preparedness Act for Medical Countermeasures Against COVID–19

Under Standard Practice:

  • Under supervision of medical director in accordance with physician order

Under DCA Waiver:

  • May independently prescribe and administer COVID-19 vaccines in association with a state, local, or institutional vaccination effort;

  • Must complete the CDPH-prescribed immunization training programs;

  • Must have documentation of an observation period by a currently-practicing healthcare professional experienced in administering intramuscular injections, for whom administering vaccines is within their ordinary scope of practice, and who confirms competency of the respiratory care practitioner in preparing and administering the vaccine;

  • When administering vaccine, must be supervised by a currently-practicing healthcare professional who is experienced in administering intramuscular injections;

  • Must be certified in basic cardiopulmonary resuscitation;

  • Must comply with federal and state recordkeeping and reporting requirements; 

  • Must comply with applicable requirements of the CDC COVID-19 vaccine provider agreement; and,

  • Vaccine must be administered in accordance with applicable FDA emergency use authorization or license.

Respiratory Care Practitioner Students

Respiratory Care Board of California 

BPC § 3741 & 3742

Order Waiving Restrictions On Healthcare Students Administering COVID-19 Vaccines In Association With State Or Local Vaccination Efforts (dated 3/30/21)

Federal HHS Resource:
Seventh Amendment to Declaration Under the Public Readiness and Emergency Preparedness Act for Medical Countermeasures Against COVID–19


Under Standard Practice:

  • When enrolled in an approved respiratory care training program, during the period of clinical training, when services are incidental to the course of study, and under direct supervision of licensed respiratory care practitioner.

Under DCA Waiver:

  • May administer COVID-19 vaccines in association with a state, local, or institutional vaccination effort;

  • Must be trained in administering vaccines, as determined by the student's school or training program;

  • Must complete the CDPH-prescribed immunization training programs;

  • Must have documentation of an observation period by a currently-practicing healthcare professional experienced in administering intramuscular injections, for whom administering vaccines is within their ordinary scope of practice, and who confirms competency of the student in administering the vaccine;

  • When administering vaccine, must be supervised by a currently-practicing healthcare professional who is experienced in administering intramuscular injections;

  • Must be certified in basic cardiopulmonary resuscitation;

  • Supervisor must comply with federal and state recordkeeping and reporting requirements; 

  •  Must comply with applicable requirements of the CDC COVID-19 vaccine provider agreement; and,

  • Vaccine must be administered in accordance with applicable FDA emergency use authorization or license.

Psychiatric Technicians and Students

​​Licensee*

​Authorizing Statutes & Regulations

​Conditions for Immunizing

​Psychiatric Technician

Board of Vocational Nursing and Psychiatric Technicians

BPC §§ 4502.1 & 4502.3

  • When working in a mental health facility or developmental disability facility and prescribed by a physician and surgeon.

  • On a patient with a mental illness or developmental disability, upon standing orders of a supervising physician and surgeon or pursuant to written guidelines adopted by a hospital or medical group with whom the supervising physician and surgeon is associated.

​Psychiatric Technician Students

Board of Vocational Nursing and Psychiatric Technicians

BPC § 4509.5

  • Only when pursuant to a course of training for licensure as a psychiatric technician in a Board-approved school.

Veterinarians and Veterinary Students

​​Licensee*

​Authorizing Statutes & Regulations

​Conditions for Immunizing

​Veterinarians

Veterinary Medical Board

Order Waiving Restrictions On Licensed Midwives, Physician Assistants, Respiratory Care Practitioners, And Veterinarians Ordering And Administering COVID-19 Vaccines In Association With State Or Local Vaccination Efforts (dated 3/30/21)

Federal HHS Resource:
Seventh Amendment to Declaration Under the Public Readiness and Emergency Preparedness Act for Medical Countermeasures Against COVID–19

  • May independently prescribe and administer COVID-19 vaccines in association with a state, local, or institutional vaccination effort;

  • Must complete the CDPH-prescribed immunization training programs;

  • Must have documentation of an observation period by a currently-practicing healthcare professional experienced in administering intramuscular injections, for whom administering vaccines is within their ordinary scope of practice, and who confirms competency of the veterinarian in preparing and administering the vaccine;

  • When administering vaccine, must be supervised by a currently-practicing healthcare professional who is experienced in administering intramuscular injections;

  • Must be certified in basic cardiopulmonary resuscitation;

  • Must comply with federal and state recordkeeping and reporting requirements; 

  • Must comply with applicable requirements of the CDC COVID-19 vaccine provider agreement; and,

  • Vaccine must be administered in accordance with applicable FDA emergency use authorization or license.

Veterinarian Students

Veterinary Medical Board

Order Waiving Restrictions On Healthcare Students Administering COVID-19 Vaccines In Association With State Or Local Vaccination Efforts (dated 3/30/21)

Federal HHS Resource:
Seventh Amendment to Declaration Under the Public Readiness and Emergency Preparedness Act for Medical Countermeasures Against COVID–19

  • May administer COVID-19 vaccines in association with a state, local, or institutional vaccination effort;

  • Must be trained in administering vaccines, as determined by the student's school or training program;

  • Must complete the CDPH-prescribed immunization training programs;

  • Must have documentation of an observation period by a currently-practicing healthcare professional experienced in administering intramuscular injections, for whom administering vaccines is within their ordinary scope of practice, and who confirms competency of the student in administering the vaccine;

  • When administering vaccine, must be supervised by a currently-practicing healthcare professional who is experienced in administering intramuscular injections;

  • Must be certified in basic cardiopulmonary resuscitation;

  • Supervisor must comply with federal and state recordkeeping and reporting requirements; 

  • Must comply with applicable requirements of the CDC COVID-19 vaccine provider agreement; and,

  • Vaccine must be administered in accordance with applicable FDA emergency use authorization or license.

Individuals with An Inactive, Expired, Or Lapsed License As A Physician and Surgeon, Registered Nurse, Pharmacist, Midwife, Respiratory Care Practitioner, Dentist, Physician Assistant, Podiatrist, Optometrist, or Veterinarian

​​Licensee*

​Authorizing Statutes & Regulations

​Conditions for Immunizing

Individuals with an Inactive, Expired, or Lapsed License as a Physician and Surgeon, Registered Nurse, Pharmacist, Midwife, Respiratory Care Practitioner, Dentist, Physician Assistant, Podiatrist, Optometrist, or Veterinarian

Order Waiving Restrictions On Healthcare Providers With Expired, Inactive Or Lapsed Licenses Ordering And Administering COVID-19 Vaccines In Association With State Or Local Vaccination Efforts (dated 3/30/21)

Federal HHS Resource:
Seventh Amendment to Declaration Under the Public Readiness and Emergency Preparedness Act for Medical Countermeasures Against COVID–19

  • May independently prescribe and administer COVID-19 vaccines in association with a state, local, or institutional vaccination effort;

  • Within the last five years, held an active license or certification as a physician and surgeon, registered nurse, pharmacist, midwife, respiratory care practitioner, dentist, physician assistant, podiatrist, optometrist, or veterinarian;

  • License was active and in good standing prior to the date it went inactive, expired or lapsed, and it was not revoked or surrendered;

  • Must complete the CDPH-prescribed immunization training programs;

  • Must have documentation of an observation period by a currently-practicing healthcare professional experienced in administering intramuscular injections, for whom administering vaccines is within their ordinary scope of practice, and who confirms competency of the inactive, expired, or lapsed licensee in preparing and administering the vaccine;

  • When administering vaccine, must be supervised by a currently-practicing healthcare professional who is experienced in administering intramuscular injections;

  • Must be certified in basic cardiopulmonary resuscitation;

  • Must comply with federal and state recordkeeping and reporting requirements; 

  • Must comply with applicable requirements of the CDC COVID-19 vaccine provider agreement; and,

  • Vaccine must be administered in accordance with applicable FDA emergency use authorization or license.


‡ Provider scope of practice issues are under the jurisdiction of the Department of Consumer Affairs. CDPH does not license these professions. CDPH defers to DCA for comprehensive, authoritative legal review of provider authority to administer vaccines.

*For all out-of-state healthcare professionals of all license types: if authorized to administer vaccines in another state, the healthcare professional can administer the Covid-19 vaccine in California per the Fifth Amendment to the Declaration Under the Public Readiness and Emergency Preparedness Act ("PREP Act") for Medical Countermeasures Against COVID–19 (dated January 28, 2021). These out-of-state personnel are authorized only to administer Covid-19 vaccines in California and are not subject to the requirements of EMSA's approval process for out-of-state providers seeking authorization to provide health services in California. However, if the out-of-state provider performs any function under their healthcare license or certificate other than administering Covid-19 vaccines, they are subject to EMSA's out-of-state requirements and require a waiver to practice within California.

Last Revised: April 2, 2021




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