Biden Administration Authorizes DPMs, Students to Administer COVID-19 Vaccine | News | APMA
Biden Administration Authorizes DPMs, Students to Administer COVID-19 Vaccine

March 17, 2021

COVID-19 vaccine

Under President Biden’s direction, the US Department of Health and Human Services (HHS) expanded the class of medical professionals and health-care students who may serve as vaccinators to include licensed doctors of podiatric medicine, recently retired podiatric physicians, and podiatric medical students. 

As previously reported, APMA has been advocating to include DPMs and students in the pool of professionals who can serve as vaccinators at both the state and federal level, including writing to the National Governors Association, assisting state components, and meeting with HHS.

On March 11, HHS made an amendment to the Public Readiness and Emergency Preparedness (PREP) Act Declaration to allow more qualified professionals to prescribe, dispense, and administer COVID-19 vaccinations. The latest PREP Act amendment applies to doctors of podiatric medicine (DPM) licensed in any state, as well as any podiatrist who has held an active license or certification under the law of any state within the last five years that is inactive and was in good standing on the date it became inactive. The amendment also includes podiatric medical students with appropriate training in administering vaccines as determined by their school or training program and supervision by a currently practicing health-care professional experienced in administering intramuscular injections who administers COVID-19 vaccines.

Additional qualifications apply for all health-care providers, including DPMs, retired DPMs, and students, such as completion of a CDC training course and current certification in basic cardiopulmonary resuscitation, among others. Subject to certain limitations, a covered person is immune from suit and liability under federal and state law with respect to all claims for loss resulting from the administration or use of a covered countermeasure (i.e., administration of the COVID-19 vaccine) if a declaration under the PREP Act has been issued with respect to such countermeasure.

HHS has determined that the PREP Act clearly preempts state law. Therefore, regardless of scope-of-practice restrictions, DPMs, retired DPMs, and students may serve as vaccinators so long as they meet certain conditions. Ultimately, states and territories may choose which qualified persons to use for vaccinations in their jurisdiction.

Jurisdictions that seek to augment their vaccination workforce can use the expanded authorization and liability protections afforded under the PREP Act to include additional categories of health-care providers and students, including DPMs and podiatric medical students, to administer FDA-authorized COVID-19 vaccines. However, requirements that do not effectively prohibit qualified persons, such as additional training, are not preempted.

The Biden administration also launched an online vaccinator portal for providers and students to determine eligibility and find vaccination management sites; for more information, visit

Additional Resources from HHS:

This resource is for information purposes only. APMA is not rendering legal advice and advises doctors of podiatric medicine to speak with an attorney duly licensed in their jurisdiction.

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