What to Know About Pharmacy Technician-Administered Immunizations
The authority for pharmacy technicians to administer immunizations has come on fast. The first state to approve technician immunizations was Idaho in 2017, and other states have quickly followed suit. As pharmacists and also pharmacy technicians, we know that technician roles are expanding and technician-administered immunizations are here to stay. But most boards of pharmacy are not yet allowing technicians to independently administer vaccines. That raises the question: Who is liable for a technician-administered immunization?
While this is a new regulatory scenario that will likely evolve, let’s look at what we know so far.
Technician vs. pharmacist liability
In most states, including my home state of Florida, technicians can give vaccines but only under the supervision of a pharmacist. As a pharmacist, this gives you both the right and responsibility to observe and ensure technicians vaccinating in your facility are vaccinating correctly and safely.
Note, though, that financial liability directed toward a healthcare provider for administering vaccines is somewhat limited, due to the National Vaccine Injury Compensation Program, or VICP. Established in 1986, and covering vaccine-related injuries since 1988, the program provides a “no-fault alternative to the traditional tort system.”
Depending on the vaccine, this includes liability for vaccine reactions, shoulder injuries related to administration, and even reactivation of the disease in immunodeficient patients who receive live vaccines. There are several important things to note about liability and the VICP:
If a claim is denied by VICP, the patient could still file a civil lawsuit, though this is rare.
Not every vaccine is covered. Some vaccines, like Japanese encephalitis and yellow fever, are not on this list.
While the COVID-19 vaccine is also not currently covered under the VICP, it is covered under the Countermeasures Injury Compensation Program (CICP).
The VICP does not protect you from disciplinary action by the Board of Pharmacy. For example, California specifically states in a letter to the medical community that incorrect administration or distribution of the COVID-19 vaccine could be subject to disciplinary action.
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Protecting yourself from liability
While it might still be unclear who would be ultimately liable for an incorrectly administered vaccine, there are several steps you can take now to improve vaccine safety and reduce liability in your pharmacy.
A good first step would be to observe each new technician give a vaccine before allowing them to do so independently. It’s also a good idea to ensure their full understanding of other aspects of vaccine administration, including vaccine formulations (such as pediatric versus adult hepatitis vaccines), preventing shoulder injuries when giving vaccines, common preventable errors, proper storage and handling, and deciding when patients should be referred to the pharmacist (like when a patient has an adverse reaction to a vaccine).
For companies, establishing an initial vaccine orientation program for technicians to check skills and knowledge after their formal vaccine training course, and then conducting periodic assessments will ensure consistency and provide clear documentation that the technicians were trained and supervised. Just like with sterile compounding — where facilities require training, orientation, competency testing, and media-fill testing prior to being able to work independently, regardless of prior experience — a vaccine orientation program can make everyone feel confident in the abilities of vaccinators at the site.
If you do have specific concerns, though, it’s a good idea to bring it up with the pharmacy manager, the regional manager, or both, so that they can weigh in, address them, and reassign duties if needed. Sending an email initially, rather than telling them in person, ensures there is a record that you brought those concerns up with management. In the meantime, if there are concerns about a specific technician administering vaccines, it is the pharmacist’s role to step in and give the vaccine instead.
The bottom line
With technician-administered vaccines quickly becoming a standard of practice in community pharmacies across the country, now is a good time to assess your procedures to ensure patient safety and also to minimize liability. With a good orientation and competency program, as well as good communication with technicians giving vaccines, your facility will be set up for success.
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