PREP Act Declaration Expanded to Cover PA Students in COVID-19 Vaccination Rollout

Photo Credits: Courtesy of CSUMB MSPA students and Jason Hrdina, UNC PA program

PA students around the country will now be able to participate in COVID-19 vaccination efforts without concerns about legal liability, thanks to an amendment to a Public Readiness and Emergency Preparedness (PREP) Act declaration issued last week by the Department of Health and Human Services. PAEA lobbied for this action through its participation in the Students Assist America (SAA) initiative, a coalition of 11 health professions education organizations that has advocated for students in several health professions to be allowed to help alleviate the burden on the health system caused by the COVID pandemic and now the massive vaccination rollout. (Read SAA’s release here.)

“We are so pleased that this decision by HHS will make it easier for PA students and other health professions students to provide the additional manpower that the health system so badly needs at this moment,” said PAEA CEO Mary Jo Bondy, DHEd, PA-C, who has represented PAEA to the SAA group. “We are especially grateful that HHS has adopted the interprofessional approach for which we advocated and allowed students to be supervised by practicing clinicians in other professions.”

The HHS action amends a PREP Act declaration that was first issued at the beginning of the pandemic, more than a year ago. The latest amendment covers “any medical, nursing, pharmacy, pharmacy intern, midwife, paramedic, advanced or intermediate EMT, physician assistant, respiratory therapy, dental, podiatry, optometry or veterinary student with appropriate training in administering vaccines as determined by his or her school or training program and supervision by a currently practicing healthcare professional experienced in administering intramuscular injections … .” The amendment preempts any state law that would otherwise limit the ability of students to administer COVID-19 vaccines.

To participate, students must document that they have completed the Centers for Disease Control and Prevention COVID-19 Vaccine Training Modules, in addition to any training required by their state. Additionally, students must also have documentation of an observation period by a supervising clinician and have a current certificate in basic cardiopulmonary resuscitation, among other requirements.

PA students from several programs have participated in vaccination efforts even prior to this HHS decision, but can now do so with reduced concerns about possible legal liability.

Members with questions regarding this policy change should contact Tyler Smith, PAEA director of government relations, at