Below are answers to commonly asked questions about the 2021 scope expansion allowing California licensed dentists to administer flu and COVID-19 vaccines to individuals aged three and older. This recent scope expansion was a result of CDA-sponsored advocacy with Dr. Jim Wood (D- Healdsburg).
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 administrative requirements in accordance with the FDA authorizations.
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 training. Please use this troubleshooting guide that illustrates how to complete the training and print certificates of completion for the training provided.
Dentists may vaccinate individuals three years of age or older against flu and COVID-19 following FDA authorizations.
An overview of immunization information systems (IISs), also known as “vaccine registries” can be found here.
While these topics will be covered in the mandated training, 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) has 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:
Information uploaded into the state vaccine registry will be able to be reviewed by patients’ primary care physicians.
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 California Dental Practice Act 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.
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 hospitals, clinics, 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 another professional advisor.
The administration of the COVID-19 vaccine when provided in accordance with the waiver requirements is 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 extended coverage and provide a copy of the new California law extending the scope of practice of dentists to include vaccine administration. 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 pertaining to COVID-19 vaccines 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 March 1, 2022.
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