After our last blog on PRS Partners with NPTA to Expand Independent Pharmacies Role in Delivering COVID-19 Vaccines and Testing Services (12/14/2020), we wanted to go over the general requirements outlined in the Department of Health and Human Services Guidance.

On October 20th, the Department of Health and Human Services released the Guidance for PREP Act Coverage for Qualified Pharmacy Technicians and State-Authorized Pharmacy Interns for Childhood Vaccines, COVID-19 Vaccines, and COVID-19 Testing.  As the title suggests, this guidance lays out a pathway for a  “Qualified Pharmacy Technician” to administer the COVID-19 and childhood vaccines.

The Federal government understands the importance of Pharmacies, Pharmacists, and those working under their direct supervision: “Pharmacists and their staff are critical to the COVID-19 response,” said Assistant Secretary for Health ADM Brett P. Giroir, M.D. “Together with pediatricians and family physicians, they are ensuring that Americans receive the vaccines they need where they need it.”  View Full Article Here

What about my State?

Now before you say, “my state does not permit Pharmacy Technicians to administer vaccines.”, the guidance states  the following on page 4, “This authorization preempts any state and local law that prohibits or effectively prohibits those who satisfy these requirements from administering COVID-19 or routine childhood vaccines.” However, as Pharmacy Owners, Pharmacists, and Pharmacy Technicians, we still need to follow our individual State Board of Pharmacy’s rules.  PRS  always recommends you review any announcements from your Board since October 20th to see if they have issued any guidance, and if not, give them a call or send them an email.  The guidance does not preempt any State laws that permit additional individuals to provide COVID-19 or childhood vaccines.

The Requirements in the Guidance

The guidance provides several items the Supervising Pharmacist and the Qualified Pharmacy Technician must comply with before and after Immunization.  In most cases, these will look very similar to how most Pharmacists became able to administer vaccines.

Before Administering a Vaccine

  • The Supervising Pharmacist must be qualified in their State to administer vaccines
  • The Technician must be registered or licensed in the State. If the State does not require registration or licensure, the Technician must be a Certified Pharmacy Technician (CPhT).
  • The Technician must also complete at least two hours of CE’s relevant to immunizations during the licensing period
  • The Technician must go through a training program that is approved by the ACPE
  • The Technician must have a current certification for CPR
  • The Supervising Pharmacist must review the State Immunization Registry before ordering the vaccination
  • The Supervising Pharmacist must order the Vaccine (for this authorization, the Vaccine must be a childhood vaccine on the ACIP Schedule for patients 3 to 18 years of age, or the Vaccine must be for the COVID-19 Vaccine for patients 3 years of age and older)
    • The Vaccine must also be FDA-licensed or have FDA-authorization.
    • The Vaccine must be ordered and administered according to ACIP Guidelines
  • The Supervising Pharmacist must be readily and immediately available
  • Comply with any of the requirements and conditions in the CDC and State’s COVID-19 Vaccination Provider Agreement

After Administering the Vaccine

  • The Technician must, if the patient is 18 years of age or younger, inform the patient and the adult caregiver accompanying the patient of the importance of a well-child visit with a pediatrician or other licensed primary-care provider and refer patients as appropriate
  • The Supervising Pharmacist must report the administration on the State Immunization Registry and to the PCP (or Pediatrician).
  • The Supervising Pharmacist is responsible for addressing and reporting adverse events
  • The Supervising Pharmacist must comply with a all record keeping requirements
  • Comply with any of the requirements and conditions in the CDC and State’s COVID-19 Vaccination Provider Agreement

Next Step

Once you have decided to let your Technician administer vaccines, you need to get them certified via a training program approved for Technicians by the ACPE and ensure they have CPR certification.  At that point, they are ready to begin administering the COVID-19 vaccine (whenever you start receiving it) and childhood vaccines.


PRS has partnered with the National Pharmacy Technician Association (NPTA) to offer a program designed to rapidly train Pharmacy technicians to administer COVID-19 vaccines and childhood vaccines.  Under the guidance of the U.S. Department of Health and Human Services, this new program, developed by NPTA, is expected to train hundreds of thousands of Pharmacy technicians within the next few weeks to distribute this much-needed vaccine quickly.  You can find some additional information and a link to the program here.