COA is urging optometrists to complete the training that will make them eligible to administer the vaccines under the public health emergency waiver that was granted because of COA’s advocacy efforts.
The California Department of Consumer Affairs (DCA), approved a public health emergency waiver that will allow doctors of optometry to order and administer COVID-19 vaccines to persons 16 years of age or older (18 years or older for Moderna vaccine) and, in cases involving a severe allergic reaction, epinephrine or diphenhydramine by injection, if they meet the following conditions:
Complete an immunization training program endorsed by the federal Centers for Disease Control and Prevention or the Accreditation Council for Pharmacy Education that, at a minimum, includes hands-on injection technique, clinical evaluation of indications and contraindications of vaccines, and the recognition and treatment of emergency reactions to vaccines, and maintains that training;
The optometrist successfully completes the required COVID-19 training programs prescribed by the California Department of Public Health at the following website:
https://www.cdph.ca.gov/Programs/CID/DCDC/Pages/Immunization/COVIDTraining-Non-Traditional.aspx;
The optometrist is certified in basic life support;
The optometrist complies with all state and federal record keeping and reporting requirements, including providing documentation to the patient’s primary care provider and entering information in the appropriate immunization information system designated by the immunization branch of the State Department of Public Health; and,
The subject vaccine is administered in accordance with any applicable FDA emergency use authorization or license.
There are three training requirements:
20-hour course – Includes 12 hours online self-study and 8 hours lecture/injection technique (includes an on-line test).
Certified in Basic Life Support
Ca Dept of Public Health (CDPH) self-study on COVID-19 vaccine – https://www.cdph.ca.gov/Programs/CID/DCDC/Pages/Immunization/COVIDTraining-Non-Traditional.aspx
To get CE credit, you must enroll in Training and Continuing Education Online (TCEO). Click the CME (physicians) option as California allows physician CME credit to count as optometry CE (See limitations).
Take a screenshot of your completion as a backup record.
The student administers vaccines in association with a State, local, or institutional COVID-19 vaccination effort;
The student is appropriately trained in administering vaccines, as determined by the student’s school or training program;
When administering vaccines, the student is supervised by a currently-practicing healthcare professional who is experienced in administering intramuscular injections;
The student successfully completes the required COVID-19 training programs prescribed by the California Department of Public Health at the following website:
https://www.cdph.ca.gov/Programs/CID/DCDC/Pages/Immunization/CO VIDTraining-Non-Traditional.aspx;
The student has documentation of an observation period by a currently-practicing healthcare professional experienced in administering intramuscular injections, and for whom administering vaccinations is in their ordinary scope of practice, who confirms competency of the student in administration of the subject COVID-19 vaccines;
The student has a current certificate in basic cardiopulmonary resuscitation;
The student’s supervisor complies with all applicable federal and state record keeping and reporting requirements, including providing documentation to the patient’s primary care provider, as applicable, and entering information in the appropriate immunization information system designated by the immunization branch of the State Department of Public Health;
The student complies with any applicable requirements (or conditions of use) as set forth in the Centers for Disease Control and Prevention COVID- 19 vaccination provider agreement;
The subject vaccine is authorized, approved, or licensed by the federal Food and Drug Administration (FDA); and,
The subject vaccine is administered in accordance with any applicable FDA emergency use authorization or license.
No. The federal law is written in a way to defer to states if they choose to impose additional training requirements.
Basic Life Support. It renews every other year. You do not need to take certification in blood borne pathogens.
No, there is no certification required by the State Board of Optometry for COVID-19 vaccine.
Not at this time. However, COA is advocating for those that passed the NBEO injection exam to not be required to take the 20-hour course.
At this time, it is unlikely that optometrists will be able to vaccinate individuals within their optometric office due to vaccine shortages. Optometrists 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.
If you are part of a medical group with an existing vaccination clinic, speak with your clinic director. If you are not part of a medical group with an existing vaccination clinic, connect with your county department of public health. They can direct you to clinics in need of providers.
Please sign-up through My Turn - Volunteer
You can also sign up for California’s Health Corps here: https://covid19.ca.gov/healthcorps/
LA County has its own volunteer sign up: http://publichealth.lacounty.gov/acd/ncorona2019/vaccine/volunteertovaccinate/
Orange County has its own volunteer sign up: https://forms.office.com/Pages/ResponsePage.aspx?id=VppE5D3NukCuMiWmPeqrO5-DmK2VQkhJrbIxNlKGGRlUOERBMklGRFo3TzhXU0pWWloyWlVSQUxWUi4u
Vaccination is an important conversation to have regardless of if you plan to administer vaccine yourself. Sharing that you got vaccinated and why can help.
Many people are under misinformation. They think the vaccine will give them COVID-19. Educate them that there is no part of the disease in the vaccine. Let them know that the side effects are much rarer, and short lived - and much more treatable than COVID-19 symptoms. The vaccines were not rushed. They were a product of international coordination and they have been independently verified that they are safe. The vaccine will not change your DNA.
The CDC website has some good information to give patients.
WebMD has launched the WebMD Covid-19 Vaccine Misinformation Center to help combat inaccuracies with facts.
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:
Optometrists 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.
While the waiver allows for optometrists to administer the vaccine to people as young as 16, optometrists must also adhere to the limitations of each approved vaccine. The Moderna and Janssen vaccine have only been approved for individuals aged 18 and over. However, the Pfizer vaccine has been approved for individuals aged 16 and over.
In cases of severe allergic reaction, optometrists are also permitted to administer epinephrine or diphenhydramine by injection. You are required to have at least three (3) epi-pens or autoinjectors on premises if you do vaccination in your office.
There is no law preventing you from vaccinating yourself. Check the policy at your vaccination site.
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 optometrists, 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 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 the vaccines:
As more vaccination clinics are established throughout the state, we expect to be provided with additional guidance on what, if anything, optometrists 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.
On March 15, CMS increased the Medicare payment amount for administering the COVID-19 vaccine. This new and higher payment rate will support important actions taken by providers that are designed to increase the number of vaccines they can furnish each day, including establishing new or growing existing vaccination sites, conducting patient outreach and education, and hiring additional staff. At a time when vaccine supply is growing, CMS is supporting provider efforts to expand capacity and ensure that all Americans can be vaccinated against COVID-19 as soon as possible.
Effective for COVID-19 vaccines administered on or after March 15, 2021, the national average payment rate for physicians, hospitals, pharmacies, and many other immunizers will be $40 to administer each dose of a COVID-19 vaccine. This represents an increase from approximately $28 to $40 for the administration of single-dose vaccines and an increase from approximately $45 to $80 for the administration of COVID-19 vaccines requiring two doses. The exact payment rate for administration of each dose of a COVID-19 vaccine will depend on the type of entity that furnishes the service and will be geographically adjusted based on where the service is furnished.
These updates to the Medicare payment rate for COVID-19 vaccine administration reflect new information about the costs involved in administering the vaccine for different types of providers and suppliers, and the additional resources necessary to ensure the vaccine is administered safely and appropriately.
CMS is updating the set of toolkits for providers, states, and insurers to help the health care system swiftly administer the vaccine with these new Medicare payment rates. These resources are designed to increase the number of providers that can administer the vaccine, ensure adequate payment for administering the vaccine to Medicare beneficiaries, and make it clear that no beneficiary, whether covered by private insurance, Medicare, or Medicaid, should pay cost-sharing for the administration of the COVID-19 vaccine.
Coverage of COVID-19 Vaccines:
As a condition of receiving free COVID-19 vaccines from the federal government, vaccine providers are prohibited from charging patients any amount for administration of the vaccine. To ensure broad and consistent coverage across programs and payers, the toolkits have specific information for several programs, including:
Medicare: Beneficiaries with Medicare pay nothing for COVID-19 vaccines and there is no applicable copayment, coinsurance, or deductible.
Medicare Advantage (MA): For calendar years 2020 and 2021, Medicare will pay providers directly for the COVID-19 vaccine (if they do not receive it for free) and its administration for beneficiaries enrolled in MA plans. MA plans are not responsible for paying providers to administer the vaccine to MA enrollees during this time. Like beneficiaries in Original Medicare, Medicare Advantage enrollees also pay no cost-sharing for COVID-19 vaccines.
Medicaid: State Medicaid and Children’s Health Insurance Program agencies must provide vaccine administration with no cost sharing for nearly all beneficiaries during the Public Health Emergency (PHE) and at least one year after it ends. Through the American Rescue Plan Act signed by President Biden on March 11, 2021, the COVID vaccine administration will be fully federally funded. The law also provides an expansion of individuals eligible for vaccine administration coverage. There will be more information provided in upcoming updates to the Medicaid toolkit.
Private Plans: CMS, along with the Departments of Labor and Treasury, is requiring that most private health plans and issuers cover the COVID-19 vaccine and its administration, both in-network and out-of-network, with no cost sharing during the PHE. Current regulations provide that out-of-network rates must be reasonable, as compared to prevailing market rates, and reference the Medicare reimbursement rates as a potential guideline for insurance companies. In light of CMS’s increased Medicare payment rates, CMS will expect commercial carriers to continue to ensure that their rates are reasonable in comparison to prevailing market rates.
Uninsured: For individuals who are uninsured, providers may submit claims for reimbursement for administering the COVID-19 vaccine to individuals without insurance through the Provider Relief Fund, administered by the Health Resources and Services Administration (HRSA).
More Information:
Medicare COVID-19 Vaccine Shot Payment webpage: Payment for COVID-19 vaccine administration, including a list of billing codes, payment allowances, and effective dates
CDC COVID-19 Vaccination Program Provider Requirements and Support webpage: How the COVID-19 vaccine is provided at 100% no cost to recipients
The waiver does not specify which settings an optometrist can administer the vaccine. However, the optometrist 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 optometrists will be able to administer vaccines from their optometric offices at this time due to storage requirements, outstanding billing questions and lack of finalized vaccine administration plans in most counties. Optometrists 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.
Once the vaccine supply increases in the state, optometrists will be able to enroll in the California COVID-19 Vaccination Program to order, store and administer vaccines in optometric offices.
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.
For as long as the 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 COA policy.
If you are covered by a different carrier, we recommend you inquire about temporary extended coverage and provide a copy of the waiver.
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. =
Blue Shield recently announced a contract to expand vaccine distribution in California. Under the contract, Blue Shield also has wide latitude to select which healthcare providers and counties will continue to receive and administer doses in California as part of a vaccine network. There are payment incentives being offered to those that vaccinate people that are in medically underserved areas and COA is working to make sure that optometrists are on those provider panels.
For more information, watch the Ask AOA video on vaccines: https://aoa.peachnewmedia.com/store/provider/custompage.php?pageid=24
DISCLAIMER: Please note that the information and any suggestions contained in this resource represent the experience and opinions of COA. 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.