Physician associates and administration of COVID-19 vaccines

At present physician associates are not considered in law registered healthcare professionals as they are not subject to statutory regulation like doctors, nurses or other allied healthcare professionals such as paramedics and physiotherapists are.

Physician associates are able to administer medicines, including vaccines, to patients. Legally, there needs to be a prescription in place prior to a physician associate being able to administer a medication. Additionally the physician associate should be formally approved to administer medications to patients by their employer and should be able to evidence competency in the administration of medicines.

With regards to the COVID-19 vaccinations, the following are appropriate legal methods which enable physician associates to administer vaccination

Patient Specific Direction (PSD)

  • A written instruction, signed by a doctor, dentist, or other independent prescriber (from here on referred to as a “prescriber”) for medicines to be supplied and/or administered to a named patient after the prescriber has assessed the patient on an individual basis. This is sometimes referred to as a “prescription”.
  • Further information around the practicalities of PSDs can be found here.

 National Protocol

Through emergency legislation Public Health England has been able to develop a national protocol which enables a range of persons, registered and non-registered, to be able to administer the COVID-19 vaccinations and the national protocol acts as the prescription, therefore a PSD (or formal prescription) would not need to be in place if using the national protocol.

Currently two national protocols exist for the following vaccines only:

Only a registered healthcare professional can assess the patient as suitable to have the vaccine, provide information to and obtain informed consent from the patient and provide advice to the patient.

  • Physician associates are not able to take part in this process (referred to as Stage 1 in the national protocol) and therefore are unable to assess patients as suitable to receive the vaccine or consent the patient, when using the national protocol.

Once a registered healthcare professional has performed Stage 1, a physician associate can prepare, administer and record keep for the two vaccines listed above in accordance with the national protocol advice.

To work under the national protocol, you must be individual named and approved to work under the national protocol by your employer.

Physician associates cannot work under a Patient Group Direction (PGD), which is separate to the above two methods of medication administration.

In summary, physician associates:

  • Can administer vaccines under a patient specific direction (PSD) or
  • Can prepare, administer and record keep under the national protocol for the mRNA vaccine BNT162b2 (Pfizer/BioNTech) and/or AstraZeneca, (ChAdOx1-S [recombinant])
  • Cannot assess a patient as suitable to receive a COVID-19 vaccine
  • Cannot consent a patient to receive a COVID-19 vaccine under the national protocol

For more information: https://www.sps.nhs.uk/articles/using-appropriate-legal-mechanisms-for-the-administration-of-covid-19-vaccines/ 

To read our latest FAQs around adminstering medications, vaccincations, prescribing and more please go to: https://www.fparcp.co.uk/about-fpa/news/faqs-december-2020