PUBLISHER’S NOTE
mike@pharmacytechnician.org
The pharmacy industry and the scope of practice for pharmacy technicians has experienced a significant shift as a result of the Public Readiness and Emergency Preparedness Act (PREP Act) Guidance issued in October 2020. Technically, the PREP Act authorizes the Secretary of the Department of Health and Human Services to issue PREP Act declarations, which are used specifically for the purpose of providing immunity from liability. Over the past few months, we have fielded hundreds of questions regarding the PREP Act, but I wanted to provide some insight on two of the most confusing/controversial topics: My state doesn’t permit pharmacy technicians administering immunizations. The practice of pharmacy is, primarily, regulated at the state level, however federal regulations supersede state regulations, with one exception. If a state has regulations that are more permissive than a federal regulation, then the state regulation is observed. For example, qualified pharmacy technicians were already permitted to administer vaccines in certain states (like Idaho) and since they could already administer any vaccine to adult patients – the restrictions in the PREP Act Guidance does not supersede the state regulations. If, however, your state did not previously permit technicians to administer vaccines, the federal guidance from the PREP Act now (at least temporarily) supersedes the state’s policies, so long as all qualifications are met. Why are we permitted to administer non-COVID vaccines to children but not adults? This is a very interesting question – one that I actually addressed to the Deputy Secretary of HHS directly. It was explained to me that HHS knew that they were stretching the authoritative limits of the PREP Act further than they had ever been stretched due to COVID, and as a result they needed to have concrete data that justified their actions.They had data that clearly demonstrated that the immunization rates for children had significantly decreased during the pandemic and therefore, the utilization of technicians administering routine childhood vaccines could make a significant impact on this aspect of public health. Although it is suspected that non- COVID adult vaccinations are also down due to the pandemic – they did not yet have empirical data to justify inclusion into the PREP Act Guidance. It is for these reasons that HHS has authorized qualified pharmacy technicians to administer COVID-19 vaccines for all patients and additional routine vaccines for children only.
Mike Johnston, CPhT Founder & CEO, NPTA
If you have any questions, let me know.
Mike Johnston, CPhT Founder & CEO, NPTA
Nunquam non paratus. Never unprepared.
CPhT CONNECT www.pharmacy technician.org
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