covid-19, delegation, On the Job, Scope of Practice

Delegation of COVID-19 Vaccinations in Tennessee

On December 4, 2020, Tennessee governor Bill Lee issued Executive Order No. 68: An Order to Facilitate the Continued Response to COVID-19 By Increasing Health Care Resources and Capacity. In part, this order authorizes “medical assistants certified by the American Association of Medical Assistants [to be delegated] tasks that would normally be within the practical nurse scope of practice, including, but not limited to, administration of COVID-19 vaccinations.” Tasks delegable to certified medical assistants “are required to have been ordered and authorized by a Tennessee licensed practitioner with prescriptive authority” and “performed under the supervision of the delegating registered nurse.”

According to the March 20, 2018, Policy Statement: Delegation of Medical Services by the Tennessee Board of Medical Examiners, physicians are permitted to delegate to supervisees (including educated and/or trained and currently competent medical assistants) in their medical practices “tasks … of the type that a reasonably prudent physician would find within the scope of sound medical judgment to delegate.” Such delegated tasks “may only be performed while the physician is either on-site or immediately available (i.e., telephone, video conferencing) for communication and consultation, as appropriate.”

Executive Order No. 68 provides evidence that the administration of COVID-19 vaccinations is a task “that a reasonably prudent physician would find within the scope of sound medical judgment to delegate” in the medical practice or clinic to an educated and/or trained and currently competent medical assistant.

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