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FAQ’s COVID-19 Vaccinations

In Jan. 2021, the Ministry of Health changed a law under the Regulated Health Professions Act, 1991 (RHPA) to assist in the administration of the COVID-19 vaccine.

A Dec. 2021, update to the Controlled Acts regulations under the RHPA allows any person to administer a COVID-19 vaccine, if a  physician, registered nurse, nurse practitioner, or pharmacist is present and accessible to the person administering the vaccine.

Below are answers to common questions we’ve received about this change. For other nursing practice inquiries, please consult our practice resources or contact CNO’s Practice Quality team.

What do these exemptions mean?

The exemption issued in Jan. 2021 enables all RNs, RPNs, pharmacists, pharmacist interns, registered pharmacy students or pharmacy technicians to administer the COVID-19 vaccine without an order.

The exemption issued in Dec. 2021 allows any person to administer the vaccine when engaged as part of the vaccination rollout by an organization (e.g., outpatient clinic, public health unit, etc.) or an entity that has an agreement with the Minister of Health related to the administration of the COVID-19 vaccine. This exemption only applies if a physician, registered nurse, nurse practitioner, or pharmacist is present and accessible to the person administering the vaccine to discuss questions relating to, or give directions with respect to, the administration of the vaccine.

The RHPA lists controlled acts that are restricted to certain individuals to support safe patient care. An example of a controlled act is “administering a substance by injection.” Controlled acts are restricted because the public risk they pose if performed by a person that does not have the proper training.

In which settings can RNs and RPNs administer the COVID-19 vaccine without a direct order or directive?

RNs and RPNs can administer the COVID-19 vaccine without an order as long as they are working or volunteering with an organization or an entity that has an agreement with the Minister of Health related to the administration of the COVID-19 vaccine. For example, municipally run vaccination sites, hospital sites, mobile vaccination sites, pharmacies, clinics, primary care settings and community locations such as community health centres and aboriginal health access centres.

Our facility has employed a model where nurses and pharmacists are drawing up the vaccine and other health care providers are administering it? Is this against CNO’s standards?

CNO would not specifically prevent this practice as long as it is done in alignment with the principles outlined in the standards, such as the Medication practice standardCNO’s standards and guidelines are broad and principle based so they can be applied to all nurses in all practice settings.

You are encouraged to review your employer’s policies and work collaboratively with your team to address any gaps in practice to ensure safe patient care and medication practices.

Some things to consider when creating your policies around this practice may be, however not limited to:

  • How are the syringes clearly and appropriately labelled, to ensure safety?
  • What other strategies can your healthcare team implement to ensure that the patient is receiving the right medication?
  • How will is be ensured that specific requirements, such as temperature for example, are maintained as per the manufacturer’s directions?
  • How will each step be documented to ensure accountability?
  • How have you addressed any outstanding concerns with your employer in the interest of safe patient care?

Can I help if I am in the non-practising class, have a resigned membership, or am a nursing student?

Yes, you can help.

  1. You can reinstate with CNO. Former nurses or nurses in the Non-Practising Class that have practiced within the last three years may wish to reinstate their CNO membership in the General Class to assist with the pandemic efforts, including the vaccination rollout. 
  2. You can also choose to work as a UCP. Your employer would determine your role and responsibility.
  3. If you are a nursing student, you are accountable to your academic institution and placement organizations. CNO does not regulate nursing students. It is up to the host organization and the academic institution to determine student roles and responsibilities and to ensure appropriate orientation and training, not only for students, but for all staff.

To help with the administration of the COVID-19 vaccine, you can register and apply through the Ontario’s Matching Portal.

Page last reviewed January 28, 2022