covid-19, delegation, Scope of Practice

Delegation of COVID-19 Vaccinations in Oregon: Part II

In part I of this topic, I responded to a registered nurse (RN) who questioned whether language in the regulations of the Oregon Board of Nursing might prevent RNs from delegating to medical assistants the administration of COVID-19 vaccinations. The RN followed up with an additional question:

What language in the Oregon nursing law permits RNs to delegate to medical assistants the administration of intramuscular injections—including COVID-19 vaccinations?

Medical assistants are classified as unregulated assistive personnel (UAP) under the Oregon nursing law. Division 45 of the regulations of the Oregon Board of Nursing, “Standards and Scope of Practice for the Licensed Practical Nurse and the Registered Nurse,” contains the key information on medical assistants’ scope of practice:

(11) Standards related to the RN who delegates the performance of a nursing procedure to a UAP.

(e) The RN’s authorization of a UAP to perform a nursing procedure shall only occur when the following delegation process steps are met:

(A) Based on nursing judgment, the RN determines that:

(i) The procedure does not require interpretation or independent decision making during its performance on the client;

(ii) The results of performing the procedure are reasonably predictable;

(B) The RN teaches the nursing procedure to the UAP and competency validates the UAP in the safe and accurate performance of the procedure on the client.

(f) The RN shall provide clinical supervision of the UAP to whom the procedure has been delegated.  The clinical supervision shall include:

(A) Monitoring of the UAP’s performance of the procedure to verify the UAP’s adherence to written directions; and

(B) Engaging in ongoing evaluation of the client and associated data to determine the degree to which client outcomes related to performance of the procedure are being met.

My legal opinion is that Division 45—not Division 47, which was discussed in Part I—is the applicable Oregon nursing law for determining what tasks may be delegated by RNs to UAP such as medical assistants in outpatient settings, including vaccination clinics. Division 45 states that RNs are permitted to delegate to UAP nursing procedures as long as all of the conditions delineated in Division 45 are satisfied.

An intramuscular injection such as a COVID-19 vaccination is a nursing procedure. Therefore, my legal conclusion is that Oregon nursing law allows RNs to delegate to knowledgeable and competent medical assistants working under direct or on-site RN supervision the administration of COVID-19 vaccinations in outpatient vaccination clinics as long as all the requirements of nurse delegation in Division 45 are met.

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