Dispensing Vaccines on Campus
Many K-12 schools, colleges, and universities may distribute flu or COVID-19 booster vaccines on campus for both their own populations and the general public. If your institution is considering a vaccine event, consult with counsel to understand your institution’s legal responsibilities and potential liability.
Whether your institution chooses to conduct a vaccination event or provide a smaller number of vaccines through a health clinic, keep these points in mind.
Planning to Dispense Vaccines
Vaccine distribution events take planning and coordination. 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 dispense vaccines. Identify a vaccination site (field house, student center, clinic, auditorium) with easy access. Choose a location appropriate for the size of your vaccination event.
- Site details. Once you have identified your location, think about how best to set up your event. For example, will protection from the elements be available as people wait? Does the facility provide for easy access points and internal traffic flow? Identify areas for vaccine and supply storage, including ways to keep these items temperature controlled (if necessary) and secure.
- Contracts. Memorialize any agreement to serve as a vaccine dispensing point for another entity in writing in the form of either a contract, memorandum of understanding, or other written agreement. This written agreement should clarify each party’s role in providing the site, supplies, vaccine, and other responsibilities in running the vaccination dispensing site. Review this agreement with counsel for the opportunity to include an indemnification clause, shifting as much liability to the outside group as possible, to provide your institution with an additional level of protection.
- Supplies. If you are considering your own vaccine event, identify and order necessary supplies for vaccine administration and begin sourcing the needed quantities. Determine where these supplies will be secured prior to vaccination 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. Select appropriate personnel 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). Where applicable, ensure staff and any nursing or medical students are covered by professional liability insurance. 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.
In the event of an emergency requiring a mass vaccination, if your institution decides to serve as a vaccine point of dispensing (POD), create a POD plan.
After completing your vaccination dispensing 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 or dispensing plan prior to their participation.
About the Author
Heather Salko, Esq.
Manager of Risk Research
Heather oversees the development of risk research publications. Her areas of expertise include employment law, Title IX, and student mental health. Before joining the Risk Research team, she practiced employment and insurance coverage law and handled UE liability claims for more than a decade.