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New Waiver Allows Licensed Volunteers to Administer the COVID-19 Vaccine

February 5, 2021

As the COVID-19 vaccination rollout continues in Pennsylvania, it is causing further strain on the hospital systems and healthcare centers across the Commonwealth. In the months ahead, volunteers could play a vital role in the administration of millions of doses of the COVID-19 vaccine in a short time frame.

Covid-19 vaccinations can safely be administered by licensed physician and nurse volunteers who do not currently practice on the public or maintain medical malpractice insurance.

Under the Volunteer Health Services Act, 35 P.S. §§ 449.41-449.53, several health-related licensing boards under the Department of State have the authority to issue volunteer licenses to retired health care practitioners who hold an active, unrestricted license.

A volunteer license holder is authorized to practice without remuneration only in "approved clinics" or upon referral from an approved organization.

The Department requested and received a suspension of this requirement so that licensed volunteers under the State Board of Medicine, the State Board of Osteopathic Medicine and the State Board of Nursing can administer vaccinations in settings that fall outside the definition of "approved clinic," including community-based, primary-care clinics and clinics in medically underserved areas, as well as state and federally qualified health centers.

An applicant for a volunteer license is required to submit a letter signed by the director or chief operating officer of the "approved clinic" where they are volunteering. As the Department of State requested a suspension of the "approved clinics" requirement, it made sense to also request a suspension of the requirement that the volunteer provide a signed letter from the director or chief operating officer of the clinic. It is possible that vaccination sites and clinics will be located throughout the Commonwealth and may not fall within the definition of "approved clinic." Volunteer license applicants may not have the ability to obtain the required letter. Additionally, requiring a volunteer to provide this information as they move around the state to vaccination clinics creates unnecessary delays in providing vaccination services to Pennsylvanians.