There's been a lot of news around COVID-19 vaccines since they were approved by the FDA on August 27. Per the FDA, 2025-2026 COVID-19 vaccines are indicated for adults 65 and older and people 6 months to 64 years old with conditions that put them at high risk for severe illness. Here's an update on what we know and what we're still waiting for more clarity on.
Authority to order and administer vaccines
What we know: Pharmacists' authority to order and administer vaccines is regulated on a state-by-state basis. In some states, that authority is tied to an ACIP recommendation, and ACIP isn't scheduled to meet until Sept. 18 and 19, with no indication that COVID-19 vaccines are on the agenda. While we wait for that meeting, we encourage you to work with your state associations and boards of pharmacies to seek clarity on what is allowed where you practice before administering COVID-19 vaccines.
NCPA is working collaboratively with the other national pharmacy associations to support states' efforts, where needed, to decouple authority from being tied solely to ACIP or CDC recommendation and provide the option to use other evidence-based recommendations or guidelines, such as those from organizations like the American Academy of Pediatrics and the American College of Obstetricians and Gynecologists. Some states, like Maryland, New Mexico, Massachusetts, and Pennsylvania, Colorado, Washington and New York, have successfully changed laws, rules, and statewide protocols or issued executive orders to ensure patients can access COVID-19 vaccines through pharmacies.
What we don't know: It's unclear what ACIP will recommend or whether they will alter any of the high-risk conditions currently listed on the CDC website. Historically, patient attestation to having one or more high-risk conditions has been adequate proof for vaccine administration. We encourage you to use a patient intake form requiring patients under 65 years of age to attest to having one of the high-risk conditions.
Payment and coverage
What we know: Outside of Medicare Part B, mandated insurance coverage of COVID-19 vaccines is tied to an ACIP recommendation. Even if you have the authority to start vaccinating now, coverage and payment may depend upon ACIP action later this month. If you do choose to vaccinate, we encourage you to document any denied claims. Here's a reporting form you can use brought to you by the National Adult Immunization and Influenza Summit (NAIIS).
What we don't know: While organizations like AHIP have stated their member health plans intend to provide coverage of COVID-19, we don't know if they will require additional documentation or how they will handle coverage of vaccines administered "off-label."
Questions about professional liability should be directed to the company that issued your policy.
For a deeper dive and additional resources, check out this provider toolkit from the Common Health Coalition.
