Registered Nurse COVID-19 Updated Vaccine Access

In these uncertain and often concerning times of Covid-19 and the rush to vaccinate as many people as possible, the California Board of Registered Nursing (BRN) has recently declared that the ordering and administration of Covid-19 vaccination is covered under the scope of practice for RNs licensed by the BRN and includes holders of temporary licenses.  These licensees are legally authorized to independently order and administer Covid-19 vaccinations as within the RN scope of practice cited in California Business & Professions Code Section 2725.

The FDA’s Emergency Use Authorizations (EUAs) for both Pfizer and Moderna Covid-19 vaccines allow both to be administered by a licensed RN without an individual prescription for each recipient of the vaccine.  This, of course, greatly increases the speed and efficiency of vaccination of individuals throughout the state and the our hope is that it does just that.

Also of note in the Board’s latest notice is that holders of valid interim permits issued by the CA BRN may administer the Covid-19 vaccines, provided they do so under the direct supervision of a licensed RN and if done pursuant to California Code of Regulations, Title 16, Section 1414(c).

Lastly, nursing students in California may also administer the vaccine if done so pursuant to an order from a physician, RN or anyone legally authorized to order the vaccine for a patient, when giving the vaccine is incidental to the students’ course of study at a Board-approved nursing school.

All of us at Brown & Brown thank our many nurse and other healthcare clients for their continued dedication to combating the Covid-19 virus and look forward to providing continued legal updates as the regulatory landscape with regard to vaccine administration develops.


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