The NCSL Blog


By Haley Nicholson and Erik Skinner

Public polls consistently place pharmacists among the most trusted professions in the United States. Depending on the state, pharmacists can fill prescriptions, order tests, prescribe certain treatments, provide guidance to patients and administer vaccines.

hand holding vaccineEarly in the COVID-19 pandemic, the U.S. government recognized pharmacists’ unique position as a frontline provider, trusted community source and convenient point of care—and expanded their role in COVID-19 testing.

Now that several COVID-19 vaccines are in stage 3 clinical trials, states and the federal government are once again turning to pharmacists to aid in the population-wide administration of current routine vaccines and potentially a future COVID-19 vaccine.

Due to the coronavirus pandemic, many children and their families have forgone routine care including vaccinations. As the CDC reported in May, there has been a significant drop in routine childhood immunizations with more families staying home. While staying home was recommended at that time, the decrease in childhood-vaccination rates is something many states are looking to address.

On Aug. 19, the Department of Health and Human Services (HHS) issued an amendment under the Public Readiness and Emergency Preparedness Act (PREP Act) regarding vaccinations for children. The amendment authorizes state-licensed pharmacists and authorized pharmacy interns to order and administer vaccines for children ages 3 through 18 years old.

With children headed back to school in some states and flu season ahead, HHS wanted to ensure families have a variety of options to access essential care, including vaccines. This new amendment can provide states with more options to expand where families can access vaccines.

Pharmacists that decide to administer vaccines will be subject to several requirements, including:

  • Vaccines must be approved or licensed by the Food and Drug Administration (FDA).
  • The vaccine must be ordered and administered per the Centers for Disease Control and Prevention’s (CDC) Advisory Committee on Immunization Practices.
  • Pharmacists must complete a practical training program of at least 20 hours approved by the Accreditation Council for Pharmacy Education.
  • Pharmacists must comply with recordkeeping and reporting requirements in which they administer vaccines, including informing the patient’s primary-care provider when available and submitting required information to the state or local immunization information system.
  • Pharmacists must inform patients and adult caregivers on the importance of a well-child visit with a pediatrician or other licensed primary care provider, among other requirements.

States have been addressing pharmacists’ authority to administer vaccines for years. The CDC requirements are consistent with many state requirements, where licensed pharmacists already administer vaccines to children.

Every state allows pharmacists to administer vaccines in some capacity. The variation is in the types of vaccines and age groups with whom pharmacists can work. Indiana, Minnesota, West Virginia and Wisconsin enacted legislation this year authorizing pharmacists to administer specific vaccines to certain populations.

State legislatures can write their own rules, defer to the executive branch or board of health, or mandate compliance with federal guidance (often CDC or the FDA) when determining requirements for vaccine administration authority.


Haley Nicholson is senior policy director in NCSL’s Health and Human Services Program.

Email Haley

Erik Skinner is a policy associate in NCSL’s Health Program.

Email Erik

Posted in: COVID-19
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About the NCSL Blog

This blog offers updates on the National Conference of State Legislatures' research and training, the latest on federalism and the state legislative institution, and posts about state legislators and legislative staff. The blog is edited by NCSL staff and written primarily by NCSL's experts on public policy and the state legislative institution.