At the request of the NC Department of Health and Human Services (NC DHHS) , NCMB has clarified that existing state law allows a licensed physician to delegate medical tasks to an unlicensed person, as long as that individual is qualified to perform the assigned tasks. Although NCMB has not addressed the specific question of whether unlicensed individuals should administer COVID-19 vaccinations, it is NCMB’s view that this task falls within the definition of “medical tasks” that may be delegated in accordance with N.C. Gen. Stat ยง 90-18(c)(13). “Qualified” individuals could include retired physicians or other clinicians who no longer have active North Carolina professional licenses.
It is the responsibility of the licensed physician delegating the task of administering vaccine to determine that the individual performing the task is, in fact, appropriately trained and competent, and the delegating physician would be held ultimately responsible for the actions of the unlicensed person. NCMB advises that this be taken into consideration when determining the appropriate level of supervision (direct, on-site, or remote).
More information about delegation can be found here.
Unlicensed professionals who want to participate in the vaccination efforts should register with NC DHHS and NC DPS/Emergency Management by visiting NC Terms.
