Act 769 of 2014 Legislature & Pharmacist Immunization Recordkeeping

Act 769 of the 2014 Louisiana Legislature, effective August 1, 2014, expanded the list of immunizations and vaccines that a pharmacist may administer without the necessity of a prescription or medical order.  This law permits a pharmacist, once properly credentialed by the Board, to administer any immunization or vaccine to any individual age seventeen or older (except influenza may be administered to any individual age seven or older) provided the immunization or vaccine is administered in conformance with the most recently published immunization administration protocol from the United States (U.S.) Centers for Disease Control and Prevention's (CDC) Advisory Committee on Immunization Practice (ACIP).  At the time the pharmacist administers the immunization or vaccine, the pharmacist shall inform the patient the administration of the immunization or vaccine should not be construed as a substitute for an annual checkup with the individual's primary care or family physician.

The law requires the immunizing pharmacist to comply with a number of other provisions:

1. The pharmacist shall obtain the appropriate credentials (Medication Administration Registration) from the Board prior to administering any medication.
2. Prior to administering an immunization to a patient, the pharmacist shall request the name of the patient's primary care provider.  The pharmacist shall notify that provider of the patient's immunization by written or electronic communication as soon as reasonably possible thereafter.
3. The pharmacist shall report each immunization to the Dept. of Health & Hospital (DHH) Office of Public Health's (OPH) Louisiana Immunization Network for Kids Statewide (LINKS) at the time of immunization or as soon as reasonably practicable thereafter since this is the official state vaccination record.
4. The pharmacist shall maintain a record of each immunization administered for at least two years thereafter.
5. The pharmacist shall report all adverse events he observes or which are reported to him to the Vaccine Adverse Events Reporting System (VAERS), the cooperative program for vaccine safety administered by the US CDC and the US Food and Drug Administration (FDA), and further, the pharmacist shall refer the patient with an adverse event to an immunization for appropriate medical care.

In response to multiple inquiries from pharmacists and pharmacies relative to recordkeeping requirements for immunizations administered without a prescription or medical order from a practitioner, the Board adopted the following motion during its meeting on August 6, 2014:

Resolved, for the purpose of recordkeeping and facilitating access to immunizations for the public, and in the interest of the public's health, safety and welfare, pharmacists administering immunizations without a prescription or medical order shall create a record in their prescription files which contains a prescription number and lists the immunzing pharmacist as the prescriber.