More than three years after initially declaring a public health emergency due to the COVID-19 outbreak, both the World Health Organization (WHO) and the United States Department of Health and Human Services (HHS) recently announced an end to the public health emergency. Let’s explore what this announcement means for pharmacy technicians and their ability to administer immunizations moving forward.
Pharmacy technicians have always been key members of the pharmacy team. The COVID-19 pandemic highlighted the significant contributions that pharmacy technicians make to public health, particularly as they were at the forefront of mass vaccination efforts. Whether administering vaccines, managing inventory, scheduling appointments, or handling logistics, pharmacy technicians helped millions of Americans get vaccinated. With the end of the Public Health Emergency (PHE), how will the role of pharmacy technicians change?
When HHS first declared a public health emergency in January 2020, it granted the agency several emergency powers, including the ability to:
- Waive certain Medicare, Medicaid, and Children’s Health Insurance Program requirements to allow for more flexibility in providing healthcare services;
- Authorize emergency use of certain medical products and devices, including diagnostic tests, treatments, and vaccines, which are not yet fully approved by the FDA; and
- Provide funding and resources to state and local health departments to respond to the outbreak.
Public Readiness and Emergency Preparedness (PREP) Act
HHS also invoked the Public Readiness and Emergency Preparedness (PREP) Act which was initially passed into law in 2005. It was designed to help the United States prepare for and respond to public health emergencies. The PREP Act provides liability protection to manufacturers, distributors, and other organizations that develop and provide medical countermeasures, such as vaccines, drugs, and other treatments, in response to a public health emergency.
In October 2020, then HHS Secretary Alex Azar announced that qualified pharmacy technicians nationwide would be allowed “to administer FDA-authorized or FDA-licensed COVID-19 vaccines to persons ages three or older and to administer FDA-authorized or FDA-licensed ACIP-recommended vaccines to persons ages three through 18 according to ACIP’s standard immunization schedule.”
HHS subsequently allowed pharmacy technicians to administer seasonal influenza vaccines to adults age 19 and older. This proved to be a pivotal decision by HHS as it enabled pharmacy technicians to help vaccinate millions of individuals across the country.
Only a few states allowed pharmacy technicians to administer immunizations before the COVID-19 pandemic, with Idaho being the first state to adopt the practice. This move was somewhat controversial at the time, with skeptics insisting that pharmacy technicians were not qualified to engage in immunization administration. There were also concerns about how this would impact pharmacists’ immunization authority as some states still limit pharmacist-administered immunizations to certain vaccines and age groups. Advocates for this change noted that it was possible to train pharmacy technicians to safely perform the technical task of medication administration.
While there is still skepticism among certain groups, pharmacy technicians have clearly demonstrated the impact they can have when trained and allowed to administer vaccines. A number of articles published in pharmacy journals describe the growth in immunization training programs, increasing acceptance among pharmacists with firsthand experience working with immunizing technicians, and improvements in pharmacy workflow.
Pharmacy technicians have also expressed satisfaction with providing immunizations. Brian McKnight, CPhT-Adv, of Anchorage, Alaska stated “I never thought I would be providing vaccines to anyone, let alone a brand-new vaccine that was developed to help stop a global pandemic. In 2020 I became a technician vaccinator and when the Pfizer vaccine became available, I was able to staff mass vaccine clinics with a team of pharmacists and technicians. Through this experience, I felt truly validated as an important part of the healthcare system.”
In early 2023, HHS announced that the COVID-19 PHE would end on May 11, 2023, spurring confusion within the healthcare community about how the end of the PHE would impact liability protections that were extended through the PREP Act. It was unclear whether pharmacy technicians would still be able to administer immunizations. National pharmacy associations immediately contacted HHS to alert them to the confusion and urge them to issue clear guidance for what would happen after May.
Consequently, in April 2023, HHS Secretary Xavier Becerra announced his intent to amend the PREP Act declaration to ensure that certain pharmacy-provided COVID-19 vaccines and related health care services will continue through December 2024. This means qualified pharmacy technicians can continue administering COVID-19 and influenza vaccines through the end of next year, regardless of state law.
Recognizing that the PREP Act authorities were temporary, many state pharmacy associations, state boards of pharmacy, and state legislatures collaborated over the past few years to ensure that technicians’ immunization authority would continue beyond the pandemic. As of May 2023, 27 states have already made permanent changes to pharmacy laws and regulations. Some boards of pharmacy had the authority to do this through rulemaking processes, while others had to work with state legislators to pass legislation enabling such a change. At the time of publication, there were 20 additional states with pending legislation to codify technicians’ immunization authority.
CREDENTIAL REQUIREMENTS VARY BY STATE
States have taken different approaches to what training or credentials are required for pharmacy technicians to administer vaccines and what vaccines may be administered. In some states, pharmacy technicians must hold a national certification and may only administer COVID-19 and influenza vaccines. A few states allow pharmacy technicians to administer any injectable medication that pharmacists can administer. In all cases, pharmacy technicians must complete an immunization training program to engage in vaccine administration.
Celebrating Frontline Pharmacy Workers For Their Hard Work
Pharmacy technicians deserve endless praise for how they stepped up during a global pandemic. The reality is that they have always been vital contributors to immunization efforts, but it took a public health crisis for regulators to take notice. Pharmacy technicians have proven time and time again that they are capable of this work, and the future of pharmacy depends on it.