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FAQ’s COVID-19 Vaccinations

The Ministry of Health has changed a law under the Regulated Health Professions Act, 1991, to assist in the administration of the COVID-19 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 does it mean to have an exemption?

The Regulated Health Professions Act, 1991 (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 they can pose a risk to the public if they are performed by a person that does not have the proper training.

An exemption in the RHPA enables certain individuals to have access to a controlled act without requiring an order. In this exemption, all Registered Nurses, Registered Practical Nurses, pharmacists, pharmacist interns, registered pharmacy students or pharmacy technicians can administer the vaccine without an order. The exemption only applies if the nurse is engaged as part of the vaccination rollout by an organization (for example, 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.

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.

I am working in a COVID-19 vaccination clinic and have the authority to delegate the administration of the covid-19 vaccine to unregulated care providers. Am I responsible for their practice?

If you are delegating the controlled act of administering a vaccine to  an unregulated care provider, you have specific delegation accountabilities. For example, when the delegatee is not a regulated health professional, the nurse must be satisfied that the delegatee has the knowledge, skill and judgment to perform the controlled act safely and ethically and that the delegation is appropriate for the patient. To learn more about delegation, see CNO’s Authorizing Mechanisms practice standard.

Nurses are also accountable to intervene and use their knowledge, skill and judgment in the event of a critical incident, including adverse vaccine reactions.

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?

I have resigned from CNO but I would like to volunteer to help vaccinate. Can I do this?

Yes, you can help. You have two options:

  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 an unregulated care provider. As an unregulated care provider, any controlled acts you are performing, such as administering a substance by injection, would have to be delegated to you. More information about delegation can be found in CNO’s Authorizing Mechanisms practice standard. To help with the administration of the COVID-19 vaccine, you can register and apply through Ontario’s Matching Portal.


I am a nursing student. Am I allowed to administer the COVID-19 vaccine?

If you are a nursing student employed by an organization to administer vaccines, then you would be considered an unregulated care provider. As an unregulated care provider, any controlled acts you are performing, such as administering a substance by injection, would have to be delegated to you.  More information about delegation can be found in CNO’s Authorizing Mechanisms practice standard. These same guidelines would apply to performing nasopharyngeal swabs for testing for COVID-19.

Nursing students are accountable to their academic institutions and their 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. 

Page last reviewed April 12, 2021