March 26, 2008

Flu and Pneumonia Vaccination Procedures

On March 21, 2008, the Illinois Department of Public Health published an amendment  to the Hospital licensing rules on medications and treatments, effective immediately, to allow influenza and pneumococcal polysaccharide vaccines to be administered per medical staff-approved hospital policy that includes an assessment for contraindications.  (77 Illinois Administrative Code 250.330).

In addition, the amendment updates the rules to include certain allied health care professionals authorized to order medications and treatments.  This memo explains the amendments and offers some suggestions about its implementation.

I. EXCEPTION FOR FLU AND PNEUMONIA VACCINATIONS
Until the adoption of this amendment, Section 250.330 required that no medication, treatment or diagnostic test could be administered to a patient except on the written order of a physician. In an effort to streamline the procedures for inoculating hospital patients against flu and pneumonia, the State has adopted a rule consistent with the rule governing medication orders under the Conditions of Participation. (42 CFR 482.23). Effective March 10, 2008, influenza and pneumococcal polysaccharide vaccines may be administered per a hospital policy approved by the medical staff. Such policy must include an assessment of the patient for contraindications of providing these vaccinations.

A. Adoption of a Policy on Flu and Pneumonia Vaccinations is Voluntary.
Since the adoption of a separate policy for flu and pneumonia vaccinations is voluntary, hospitals may continue to require a written order for each individual patient, before administering flu or pneumonia vaccinations.

However, this new exception allows hospitals to develop a policy for expedited administration of these vaccines. Such a policy might incorporate a written protocol or a standing order for giving these vaccinations. The policy may provide that for each individual patient who receives an influenza or pneumococcal polysaccharide vaccination under the hospital policy, no individual written order is required. Hospitals should work with their infection control directors, the pharmacy and therapeutics committee, and the medical staff to determine the list of contraindications; who will perform assessments; and how the assessment will be documented, so that the policy addresses these issues. The medical staff must approve the policy, before it can be implemented.

B. Amended State Law Is Consistent With The CMS Conditions Of Participation.
The federal Conditions of Participation allow this same exception for flu and pneumonia vaccinations. Recent CMS interpretive guidelines clarify that initiation of such protocols for influenza and pneumococcal polysaccharide vaccines does not require an order from a practitioner responsible for the patient’s care. This amendment makes Illinois law consistent with the Conditions of Participation in this area.

II. ADDITION OF CERTAIN AUTHORIZED ALLIED HEALTH PERSONNEL
Since Physician Assistants and Advanced Practice Nurses may order medications, tests and treatments in accordance with the practice acts for those professions, this rulemaking updates the hospital licensing rules on Orders for Medications and Treatments to incorporate these allied health professionals where they have been given clinical privileges recommend by the hospital medical staff and granted by the hospital governing body:

"(a) No medication, treatment or diagnostic test shall be administered to a patient except on the written order of a member of the medical staff, or a house staff member under the supervision of a member of the medical staff, or allied health personnel with clinical privileges recommended by the hospital medical staff and granted by the hospital governing body…"

These same allied health personnel "shall give orders for medication and treatment only to the licensed, registered or certified professional persons who are authorized by law to administer or dispense the medication or treatment in the course of practicing their identified specific discipline." (77 Ill. Adm. Code 250.330).

I hope this information is helpful. To view the newly adopted rule discussed here, in its entirety, please see the attached copy of Section 250.330 (click here).