Scope of Practice

Immunization Update: Clarification of Non-Patient Specific Orders and Protocols

Earlier this year the State Education Department mailed to all registered professional nurses (RNs) in New York State the regulations and guidelines for non-patient specific orders for administration of immunizations and treatment of anaphylaxis. The original guidelines did not address the role of the licensed practical nurses (LPNs).

A second Practice Memorandum (2001.6), issued 3 October, 2001, addresses the LPN role in using non-patient specific orders for immunization along with clarification about requirements for: CPR, record keeping, and notification of primary care providers. A summary of the contents of the memorandum follows:

• CPR Certification
  
  RNs using the non-patient specific orders for immunizations must hold current CPR certification by a program of the American Red Cross or the American Heart Association or equivalent organization acceptable to the State Education Department. The State Education Department recognizes staff development or inservice departments that train individuals in CPR but do not necessarily provide certification as equivalent organizations.
  
  
• Licensed Practical Nurses Assisting in the Execution of Non-Patient Specific Orders
  
  Education Law authorizes RNs to direct the nursing care provided by LPNs. Therefore an LPN can assist in administering immunizations (give the injection, assist with record keeping, and when appropriate, administer agents for treatment of anaphylaxis) as long as the RN assesses the recipient, and is responsible for the on-site direction of the LPN. Under these circumstances, it is expected that a ratio of not more than three LPNs to one RN are maintained.

Please note: Nothing prevents an LPN, in the absence of an RN, from administering epinephrine (epi-pen) in an emergency situation, such as an anaphylactic reaction from a wasp sting or ingestion of peanut butter.

• Record Keeping
  
  Regulation requires the RN who administers the immunizations to maintain records of all persons immunized at clinics.
  
  The sponsoring agency, with the agreement of the registered professional nurse, may take responsibility for record keeping and maintenance of the immunization record.
  
  Regulation requires the RN administering immunization under a non-patient specific order to attach and maintain a copy of the immunization order and protocol with the individual record for each patient.
  
  When immunizing adults for influenza ONLY, it is acceptable to maintain a log of the names, addresses and phone numbers of the adults immunized using the non-patient specific influenza vaccine orders, placed in a dated file with a copy of the influenza order and protocol attached to the log.
  
  
• Primary Care Provider Notification
  
  Regulation requires that the registered professional nurse, with consent of the patient or legally responsible person, notify each primary care provider (when there is one) as to when the patient has been immunized using a non-patient specific order.
  
  When immunizing adults for influenza ONLY, it is acceptable to have the patient:
  
• complete a post card providing the date and location of the influenza immunization given, which can then be mailed by the nurse or sponsoring agency to the primary care provider OR
  
• sign a consent form on the certificate of immunization on which the patient agrees to take responsibility for notification by providing the primary care provider with a copy of the certificate.

When immunizing, remember the Vaccine Information Statement (VIS):

Health care providers who administer ANY vaccine containing diphtheria, tetanus, pertussis, measles, mumps, rubella, polio, hepatitis B, Hib, pneumococcal conjugate or varicella are required by law to provide a copy of the relevant Vaccine Information Statement(s) (VIS) to the patient or parent / guardian prior to each dose of the vaccine.

For questions, contact Education, Practice and Research: 518.782.9400, ext. 282

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