Licensed Washington dentists are authorized to administer COVID-19 vaccines under state law (see DQAC’s interpretive statement for more information) as well as under the U.S. Department of Health & Human Services’ (DHHS) Public Readiness and Emergency Preparedness (PREP) Act.

Washington dentists with an expired/inactive license may also administer vaccines under the DHHS PREP Act, provided the dentist’s license:

• Was active within the last five years;
• Was in good standing prior to the date it went inactive or expired;
• Was not revoked by the licensing authority, surrendered while under suspension, discipline, or investigation by a licensing authority, or surrendered following an arrest; and
• The dentist cannot be on the List of Excluded Individuals/Entities maintained by the HHS Office of Inspector General.

Dental students are authorized to administer COVID-19 vaccines under the DHHS PREP Act. Students should consult the Washington State Department of Health’s List of Providers Authorized to Administer Vaccines Chart* as well as the UW School of Dentistry for more information.

Washington dental hygienists are authorized to administer COVID-19 vaccines under current state rule.

The rule permits dentists to delegate administration of the vaccine, under close supervision, to a licensed hygienist who demonstrates the skills and competency necessary to perform the task. Hygienists are subject to the same applicable training requirements laid out in DQAC’s interpretive statement.

Additionally, in order for a hygienist to administer the vaccine, there must be a dentist on-site and the dentist must approve the vaccination protocol/screening. The dentist on-site does not need to be the employer dentist of the hygienist administering the vaccine and, under the rule, the dentist’s approval of the vaccination protocol and screening meets the requirement set by Washington state’s definition of close supervision that a dentist “personally diagnose the condition to be treated and personally authorize the procedure.”

Per DQAC’s interpretive statement, “Given the standard training and experience of dentists, ordering and administration of COVID-19 vaccination can be within the scope of practice of a dentist licensed under chapter 18.32 RCW when the treating dentist has appropriate, verifiable training and experience that includes a hands-on component.”

Dentists with active licenses should ensure the following when ordering and administering COVID-19 vaccinations.

Please note that some of these requirements do not apply when volunteering at a vaccination clinic.

• Complete appropriate education and training to administer vaccines;
• Complete the Centers for Disease and Prevention Control vaccine online training;
• Comply with the Washington State COVID-19 Vaccination Plan;
• Prior to administering a vaccine, review the patient’s vaccination history in the immunization registry;
• Ensure patient communication for informed consent;
• Ensure safe transportation and storage, including special refrigeration needs, if any;
• Consider rare adverse effects, recognition and referral;
• Report for adverse effects;
• Consider special components of medical history;
• Ensure communication with public health department regarding vaccination records;
• Comply with notification protocols for 2nd, potentially 3rd doses;
• Maintain vaccine inventory and safe disposal of unused inventory;
• Communicate and consider common side effects and management and/or referral; and
• Comply with all federal and state reporting requirements.

Per the PREP Act and further guidance from the WA Department of Health, dentists with an expired/inactive license must:

• Have documentation of completion of the Centers for Disease Control and Prevention COVID-19 Vaccine Training Modules and, if applicable, such additional training as may be required by the State, territory, locality, or Tribal area in which they are prescribing, dispensing, or administering COVID-19 vaccines.
  • The State of Washington is not requiring additional training at this time.
• Have 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 healthcare provider or student in preparation and administration of the COVID-19 vaccine(s) to be administered and, if applicable, such additional training as may be required by the State, territory, locality, or Tribal area in which they are prescribing, dispensing, or administering COVID-19 vaccines.
  • Please note that you are not required to submit this documentation to DOH or any other agency or individual. Such documentation should be maintained in your personal possession.
• Have a current certificate in basic cardiopulmonary resuscitation. This requirement is satisfied by, among other things, a certification in basic cardiopulmonary resuscitation by an online program that has received accreditation from the American Nurses Credentialing Center, the ACPE, or the Accreditation Council for Continuing Medical Education.

• Centers for Disease Control and Prevention (CDC) Vaccine Training Modules
• WA Department of Heath Training
• University of Washington Training
• Oregon Health Science University Training

If you are volunteering at a vaccination clinic, you may be able to complete a hands-on training on-site before the event begins. Be sure to inquire in advance.

Alternatively, the UW School of Dentistry has suggested the following options to complete a hands-on training:

• If you live in a major center with a health professions education center, you may be able to complete this hands-on training there.
• You may also choose to complete this training with a licensed health professional who routinely performs vaccinations — a pharmacist or nurse in your community, for example.

The PREP Act allows the Secretary of the U.S. Department of Health and Human Services (HHS) to issue a declaration that extends liability protections to entities and individuals who manufacture, distribute, or administer covered medical countermeasures against a public health threat or emergency.

In March 2020, the Secretary issued a PREP Act Declaration covering COVID-19 tests, drugs, and vaccines providing liability protections to manufacturers, distributors, SLTTs, licensed healthcare professionals, and others identified by the Secretary (qualified persons) who administer COVID-19 countermeasures. The Declaration has been amended several times to expand liability protections, including prior amendments to cover licensed healthcare professionals who cross state borders and federal response teams.

On March 12, 2021, the Acting Secretary of HHS issued the 7th Amendment to the PREP Act to extend liability protections to specified healthcare professionals who may not usually administer vaccines in their scope of practice or who have recently expired licenses, and students of specified healthcare professions who administer COVID-19 vaccines. The PREP Act also provides for a Countermeasure Injury Compensation Program for certain individuals who sustain serious injuries or die from receiving the countermeasures.

TDIC recently added an endorsement to its Professional Liability Insurance Policy that “allows dentists to prescribe and administer the COVID-19 vaccination after completing additional continuing education training.”