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Licensees Authorized to Administer Vaccines in California  

​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

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

Board of Registered Nursing

BPC § 2725


  • May independently initiate 

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) 



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:  
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.

​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



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

​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


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

​Respiratory Care Practitioner 

Respiratory Care Board of California

BPC §§ 3702 & 3703

16 CCR § 1399.364


  • Under supervision of medical director in accordance with physician order 

Respiratory Care Practitioner Students

Respiratory Care Board of California

BPC § 3741 & 3742


  • 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.
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.
​Medical Assistant
Medical Board of California

BPC § 2069

16 CCR § 1366


  • 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



​Pharmacist
Board of Pharmacy

BPC §§ 4052(a)(11) & 4052.8(a)

16 CCR § 1746.4

Federal HHS Resources:

2020-26977.pdf (govinfo.gov)


  • 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

Federal HHS Resources:

2020-26977.pdf (govinfo.gov)


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


Board of Pharmacy

 

DCA Order Waiving Restrictions on Pharmacy Technicians Relating to Administering COVID-19 Vaccines

 (Dated 12/22/20)

 

Federal HHS Resources:

2020-26977.pdf (govinfo.gov)


Guidance for PREP Act Coverage


  • ​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.

​Paramedic (for EMT see below)
​Emergency Medical Services Authority, page 54
  • ​During a public health emergency
  • Requires approval by the director of the local EMS Authority 



​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, which could include EMT scope of practice
  • 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 Board of California

 

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


  • May independently prescribe and administer COVID-19 vaccines to persons age 16 years and older
  • Must complete CDPH-prescribed immunization training programs
  • Must complete prescribed immunization training programs through the CDC
  • Must comply with federal and state recordkeeping and reporting requirements 
  • Vaccine is administered in accordance with any applicable FDA emergency use authorization 
​Registered Dental Hygienists
Dental Hygiene Board of California

 

DCA Order Waiving Restrictions on Registered Dental Hygienists Relating to Administering COVID-19 Vaccines


  • ​ 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.
​Naturopathic Doctors
Naturopathic Medicine Committee

BPC § 3640.5

16 CCR § 4236


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

​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. 

​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. 
​Medical Students
Medical Board of California 

BPC § 2064


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


 *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 updated 3/08/2021

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