6.4 Vaccine Administration: DOPL's Protocol, Delegation, Emergencies & USIIS Reporting

6.4 Vaccine Administration: DOPL's Protocol, Delegation, Emergencies & USIIS Reporting

Vaccine administration is the most common way pharmacy personnel "participate in the administration of drugs" (blueprint 2.2). Utah's framework comes from § 58-17b-102(58)(c), § 58-17b-502(1)(i), § 58-17b-620, § 58-17b-627 (vaccines are a designated public-health category), R156-17b-601(3), -606, -621, DOPL's Vaccine Administration Protocol (revised September 2023, adopted by reference in R156-17b-621(5)), and DOPL's Vaccine Administration Guidance (April 10, 2024).

Who may administer

• Pharmacists who have completed the R156-17b-621 training: current BLS, didactic and practical injection training, training on the specific products, current ACIP guidelines, and anaphylaxis management.
• Pharmacy interns and technicians, by delegation from a pharmacist who provides on-site, direct supervision. Technicians need the BLS, injection, and anaphylaxis training. Interns and technicians may not delegate administration to anyone else.
• Each person keeps documentation of training and completes two hours of vaccine-related CE each renewal cycle after initial training (R156-17b-309; R156-17b-601(3)).

What may be administered

Under the protocol, trained personnel may administer these vaccines "to eligible patients for all appropriate ages," following ACIP or state and local health department indications and contraindications:

Other vaccines, including travel vaccines such as typhoid or yellow fever, may be administered by a pharmacist under a prescription from a licensed prescriber (or under a collaborative agreement). An authorizing practitioner who signs the protocol reviews the activities of pharmacy personnel at least annually. That authorization is valid for one year unless revoked or extended, and is not needed for vaccines given under a written prescription.

2026–27 season (DOPL announcement)

Effective September 1, 2026, Utah pharmacists may prescribe and administer FDA-licensed 2026–27 inactivated, recombinant, and live-attenuated influenza vaccines and mRNA and recombinant-protein COVID-19 vaccines to eligible populations without a provider's prescription, using CDC clinical considerations, 2025–26 ACIP COVID-19 guidance, and AAP, ACOG, and AAFP guidance. Pharmacists may not administer the FDA-licensed 2026–27 mRNA influenza vaccine without a prescription or a collaborative practice agreement. The guidance expires if ACIP issues updated 2026–27 recommendations that CDC adopts.

Before administering

1. Screen the candidate or legal guardian for previous adverse events after immunization, food or drug allergies, current health conditions, recent blood or antibody products, immunosuppression, pregnancy, and underlying diseases.
2. The administering or delegating pharmacist reviews the vaccine and the screening information.
3. Inform the patient or guardian of benefits and risks and provide the current Vaccine Information Statement (VIS). Federal law (42 U.S.C. § 300aa-26) requires a VIS before each dose of a covered vaccine.

Adverse events: Utah's protocol doses

The pharmacy must post an emergency plan with the local EMS number, the authorizing practitioner's number, each participant's role, and epinephrine and diphenhydramine dosing.

Reporting and records

• VAERS: for adverse events, the administering or delegating pharmacist submits a VAERS report to the CDC, the authorizing practitioner, and the patient's primary care practitioner if known.
• USIIS: report each administered vaccine to the Utah Statewide Immunization Information System within one week of administration.
• Perpetual record: patient name; primary care practitioner (if known); vaccination date; name, address, and title of the administering or delegating pharmacist; vaccine name; manufacturer; and lot number.

Scenarios

• Senior-center clinic. A pharmacy gives 45 influenza vaccines on Monday. USIIS reporting is due within one week, not 30 days.
• Intern vaccinates. An intern with BLS and injection training vaccinates under a pharmacist standing beside the patient. This is permitted (direct, on-site supervision). An intern vaccinating while the pharmacist is off site is not.
• Anaphylaxis in a 25-kg child. Give 0.15 mg epinephrine IM, call EMS, and repeat every 5 minutes (up to 3 doses) if symptoms persist.

Exam strategy

Vaccine questions usually turn on one of four details:

1. the reporting clock: USIIS within one week;
2. the supervision level for interns and technicians: direct, on-site, with no further delegation;
3. weight-based epinephrine dosing and the 5-minute, 3-dose repeat limit; and
4. whether the vaccine is on the protocol list, in the current seasonal guidance, or needs a prescription.

Also remember the ongoing duties: two hours of vaccine CE each cycle, current BLS, and a VIS given before every dose.