Get answers to commonly asked questions regarding the emergency public health waiver issued by the Department of Consumer Affairs.
Below are answers to commonly asked questions regarding the emergency public health waiver issued by the Department of Consumer Affairs on Jan. 4, 2021 (amended Jan. 21), allowing dentists to administer COVID-19 vaccines to people age 16 and over. This FAQ will be updated as new information develops.
Dentists who wish to begin administering the COVID-19 vaccine must complete the required training, comply with all federal and state recordkeeping and reporting requirements and adhere to the administration requirements in accordance with the FDA emergency use authorization.
Please note, dentists are unable to administer vaccines in-office at this time and may only administer as a volunteer vaccinator at local community sites.
Print or save certificates to keep in your records similarly to other C.E. course certificates. At this time, you will not need to submit the certificates to any state agency.
A few tips for completing the training:
Many dentists may experience technical difficulties registering with the various systems CDC is utilizing to host their trainings. Please use this troubleshooting guide that illustrates how to complete the trainings and print certificates of completion for the trainings that provide one.
Dentists may vaccinate individuals 16 years of age or older. In cases of severe allergic reaction, dentists are also permitted to administer epinephrine or diphenhydramine by injection. The waiver is limited to any FDA-approved or Emergency Use Authorized COVID-19 vaccine.
While the DCA waiver allows for dentists to administer the vaccine to people as young as 16, dentists must also adhere to the limitations of each approved vaccine. The Moderna vaccine has only been approved for individuals aged 18 and over. However, the Pfizer vaccine has been approved for individuals aged 16 and over.
An overview of immunization information systems (IISs), also known as “vaccine registries” can be found here. However, until vaccine supply increases, registration for state vaccine registries for new providers, including dentists, is currently closed.
While these topics will be covered in the mandated trainings, the following links provide brief but detailed overviews of the storage and handling requirements for the Pfizer and Moderna vaccines:
The CDC has developed the following in-depth resources on the FDA EUAs, vaccine administration, interim clinical considerations, Advisory Committee on Immunization Practices (ACIP) recommendations and FAQs for both vaccines:
Vaccine Information Sheets (VIS) have not been developed for the COVID-19 vaccines at this time. The appropriate FDA Emergency Use Authorization Fact Sheets for Recipients listed below should be provided to patients at the time of vaccination:
As more vaccination clinics are established throughout the state, we expect to be provided with additional guidance on what, if anything, dentists will need to do aside from inputting data into the state vaccine registry in order to inform individuals’ physicians about receiving a COVID-19 vaccine.
CDA is engaged in active discussions with health plans, including dental benefit plans, to determine the most appropriate code to use when billing for the administration of the COVID-19 vaccine. CDA will keep members updated on these discussions in the CDA Newsroom.
The DCA waiver does not specify which settings a dentist can administer the vaccine. However, the dentist should ensure that all appropriate emergency response supplies are readily available and that the patient can be monitored for adverse reactions or side effects for 15 minutes after the injection.
It is unlikely that dentists will be able to administer vaccines from their dental offices at this time due to storage requirements, outstanding billing questions and lack of finalized vaccine administration plans in most counties. Dentists wishing to participate in vaccination efforts will likely be able to do so through efforts organized by government entities or local health systems and hospitals.
CDA and local dental societies are working closely with health departments and emergency medical services authorities to learn how your county is deploying health professionals to administer the vaccine in your area. CDA is continuing to advocate at the state and local level for dentists and their staff to be elevated in priority to access the vaccine and should receive at least their first dose prior to vaccinating community members.
The waiver does not have an expiration date but is expected to stand for the duration of the declared state of emergency due to the COVID-19 pandemic.
At this time, it is unlikely that dentists will be able to vaccinate individuals within their dental office due to vaccine storage requirements. It is likely for the indefinite future that dentists will be able to administer vaccines in hospital, clinic and mass vaccination sites. Additionally, because state and local vaccine roll-out plans are still in flux, there is no estimated time for when vaccines will be available to the general public.
Please note that the information and any suggestions contained in this resource represent the experience and opinions of CDA. This communication does not constitute and should not be considered a substitute for legal, financial or other advice provided by licensed professionals. For that, you must consult your own attorney, accountant or other professional advisor.
For as long as the DCA waiver is in effect, the administration of the COVID-19 vaccine when provided in accordance with the waiver requirements will be considered within the scope of practice and therefore covered under a TDIC policy.
If you are covered by a different carrier, we recommend you inquire about temporary extended coverage and provide a copy of the DCA waiver. For dentists who have reactivated their inactive or retired license, or are retired with an active license and no liability insurance, in order to help with state vaccination efforts, TDIC offers a volunteer policy where coverage can be purchased if volunteering for an organization without compensation, less any expenses.
The statutory immunities cannot prevent a claim or lawsuit from being filed against you, but can provide you with a legal defense against any such claims. In other words, the broad immunities are designed to protect you from being held liable for any claims based on administering the vaccine, so long as you are practicing within the standard of care. This includes taking the appropriate training and following all manufacturer guidance on storage and administration of the vaccine. The advantage of having a policy that specifically covers the administration of the COVID-19 vaccine is that should a claim be filed against you, the liability carrier would provide your legal defense as opposed to you finding an attorney on your own.
Last updated Jan. 29, 2021.