On January 1, 2021, the Maryland Department of Health issued an amended directive and order that, in part, permits certain individuals to administer COVID-19 vaccinations:
The following individuals may administer COVID-19 vaccines at vaccination sites:
…
D. Other individuals provided that:
a. Each individual has successfully completed training on the administration ofCOVID-19 vaccines;
b. Qualified supervisory personnel at the vaccination site reasonably determine that each individual is able to administer COVID-19 vaccines under appropriate supervision; and
c. The individual administers the COVID-19 vaccine at the vaccination site under the reasonable supervision of qualified supervisory personnel.
My legal opinion is that this category of individuals allowed to administer COVID-19 vaccinations includes knowledgeable and competent medical assistants who have completed training on the administration of COVID-19 vaccines.
Legal Eye 
Have all states done this? Mainly interested in Wisconsin.
Thank you for your question. It is my legal opinion that Wisconsin law has allowed physicians to delegate to knowledgeable and competent unlicensed professionals such as medical assistants the administration of immunizations, including COVID-19 vaccinations. I will send supporting document to your email address.
Donald A. Balasa, JD, MBA
CEO and Legal Counsel, AAMA
dbalasa@aama-ntl.org
Could you send information about montana, thank you.
Thursday, January 28, 2021
Thank you for your question. Go to http://www.aama-ntl.org and click below “State Scope of Practice Laws” near the left bottom of the homepage. You will be able to find the medical assisting law of all states, including Montana. Note the second document in the Montana subsection of our website.
It is my legal opinion that MT law permits physicians to delegate to knowledgeable and competent medical assistants working under their general supervision the administration of immunizations, including COVID-19 vaccinations. “General supervision” is defined as follows in the Montana law:
(2) “General supervision” means accepting responsibility for, and overseeing the medical services of, a physician assistant by telephone, radio, or in person as frequently as necessary considering the location, nature of practice, and experience of the physician assistant.
I hope this is helpful.
Donald A. Balasa, JD, MBA
CEO and Legal Counsel, AAMA
dbalasa@aama-ntl.org
Medical Assistants administer all types of immunizations in Utah everyday. Covid should not be any different. Allowing them to do so would sure speed up the process here. It’s moving at a snails pace right now.
Thank you for your comment. I agree with you. There is nothing in Utah law that forbids physicians from assigning to knowledgeable and unlicensed professionals such as medical assistants working under their authority the administration of COVID-19 vaccinations.
Go to http://www.aama-ntl.org and click below “State Scope of Practice Laws” near the left bottom of the homepage. You will be able to find the medical assisting law of all states, including Utah.
I hope this is helpful.
Donald A. Balasa, JD, MBA
CEO and Legal Counsel, AAMA
dbalasa@aama-ntl.org