Becoming a Point of Dispensing for COVID-19 Vaccines
December 09, 2020
Once COVID-19 vaccines created under Operation Warp Speed are given approval for wide distribution, colleges and universities in some communities may be asked to vaccinate their campus populations. Following a request from your local or state Department of Health your institution may decide to conduct a mass vaccination event for your campus community.
Before finalizing your decision, consult with counsel to understand your institution’s legal responsibilities and potential liability. While the Public Readiness and Emergency Preparedness ( PREP) Act, along with the Health and Human Services Public Declaration, may provide immunity for those distributing and administering vaccines, it is important to understand the application of the Act to the current COVID-19 pandemic and vaccination. Furthermore, state law interaction with the PREP Act is something to discuss with counsel.
Planning to Become a Point of Dispensing
A large-scale vaccine distribution event takes planning and coordination. After deciding you will serve as a vaccine point of dispensing (POD), create a POD plan such as the one at Purdue University. A well-thought-out plan will make the logistics of storage and distribution of a vaccine for your school community easier. Your plan should address:
- Overall infrastructure. Survey your institution to determine if it has the infrastructure to serve as a POD. Identify a vaccination site (field house, auditorium, large fields if vaccination will be outdoors). Choose a location appropriate for the size of your vaccination event.
- Site details. For example, will protection from the elements be available as people wait? Also consider facility access points and internal traffic flow. Identify areas for vaccine and supply storage, including ways to keep these items temperature controlled and secure.
- Supplies. Identify and order necessary supplies for vaccine administration and begin sourcing the needed quantities. Determine where these supplies will be secured prior to POD location setup. Consider other supplies to order, such as pens, paper, signage, tape, trash cans, biohazard disposal units, and hand sanitizer. Your county or state health department may have a list of necessary supplies or be able to assist with sourcing.
- Personnel. Staff appropriate personnel available to help conduct the vaccination event. If you need to rely on volunteers in addition to medical or other staff, ensure they are screened appropriately (your policy may require background checks due to the nature of the volunteer activity). Train them on your procedures as well as any safety and security precautions.
- Recordkeeping. Consult with counsel about any necessary informed consent forms that vaccine recipients must complete. Decide how those records will be maintained and securely stored.
After completing your POD plan, conduct a tabletop exercise to identify any shortcomings or potential pain points. You may need to create your own training for both leaders and on-site personnel. Train all participating staff and volunteers on the POD plan prior to their participation.
More From Canopy Programs
Your Campus and COVID-19: The Road Back
Centers for Disease Control and Prevention (CDC): COVID-19 Vaccination Program Interim Playbook
CDC: Closed Points of Dispensing Toolkit
Orange County California: POD Planning Resources
American College Heath Association (ACHA): Mass Vaccination Clinic Guidance and Resources
By Heather A. Salko, United Educators Senior Risk Management Counsel