Call:  (407) 331-6620 or (850) 439-1001
Toll-free:  (888) 331-6620 

e-book thumbnail

Seven Things To Know When You Receive A Notice Of Investigation From The Department Of Health

New Florida Legislation Allows Pharmacy Technicians to Administer Immunizations

By George F. Indest III, J.D., M.P.A., LL.M., Board Certified by The Florida Bar in Health Law

On July 1, 2022, Florida passed HB 1209, which now allows registered pharmacy technicians to administer immunizations to patients.  The new law authorizes pharmacy technicians to seek certification to provide immunizations and become “Certified Registered Pharmacy Technicians.” These pharmacy technicians will then be allowed to administer all vaccines listed by the CDC in the Adult Immunization Schedule or recommended by the CDC for international travel.  Additionally, it includes vaccines authorized by the FDA under an emergency use authorization or by the Florida Board of Pharmacy in response to a state of emergency declared by the Governor.

This is a big step in medicine, once again broadening the ability of health professionals to provide more efficient and less expensive health care. In the past, properly qualified pharmacists were allowed to administer vaccines, but even then there was a shortage.

Certification Requirements.

To become certified by the Florida Board of Pharmacy, a registered pharmacy technician must complete six hours of approved immunization-related training. As a renewal condition, an additional two hours of approved continuing education must be completed each cycle, according to the Board of Pharmacy website. For more information, click here.

In comparison, for certification, registered pharmacists must have 20 hours of education to administer vaccines. Registered pharmacist interns (persons with five years of college) who are also under the supervision of a certified pharmacist must take the same 20-hour immunization course that the pharmacists take in order to become certified to administer immunizations.

While this new Florida law seems to adopt a substantial lessening in training requirements, remember the 20-hour course is for pharmacists to administer vaccines independently.  The six-hour course is for pharmacy technicians to administer vaccines under the pharmacist‘s supervision. The technician certification program or programs authorized will have to be approved by the Florida Board of Pharmacy in consultation with the Florida Board of Medicine and the Florida Board of Osteopathic Medicine.

Stay Informed and Prepared.

The Board of Pharmacy has the authority to adopt rules to add new vaccines as added by the Centers for Disease Control (CDC) and the Food and Drug Administration (FDA), but it often takes many months to do so. Pharmacies and the pharmacistspharmacist interns, and pharmacy technicians who are responsible need to monitor these situations closely.

Pharmacies should print a copy of the CDC adult immunization schedule, the CDC’s recommended vaccines for international travel, and the FDA‘s list of vaccines with emergency use authorizations and have this easily available at all times for its staff to review.  They should also make sure to update this list at least once a month. This will help the pharmacy staff to keep on top of it if either of these federal agencies, the CDC or the FDA, changes its list of immunizations.  As we’ve seen from the COVID-19 pandemic, keeping track of vaccine schedules and emergency use authorization changes can be very confusing.

Click here to read Florida HB 1209 – Administration of Vaccines, in full

Consult With A Health Law Attorney Experienced in the Representation of Pharmacists and Pharmacies.

We routinely provide legal representation to pharmacistspharmacies, and other health professionals who have received complaints against their licenses, notices of investigations, Medicare or Medicaid audits, Drug Enforcement Administration (DEA) audits, investigations, subpoenas, search warrants and orders to show cause (OSC) or who are facing formal or informal administrative hearings.

The lawyers of The Health Law Firm are experienced in both formal and informal administrative hearings and in representing physicians, physician assistants, and other health professionals in investigations and at Board of Pharmacy hearings. Call our office now at (407) 331-6620 or toll-free at (888) 331-6620 and visit our website


Dix, Martin. “A Jump Forward For Fla. Pharmacy Technicians’ Vax Authority.” Law360. (August 19, 2022). Web.

Sexton, Christine. “Checking the pulse of Florida health care news and policy.” Florida Politics. (August 16, 2022). Web.

Dix, Martin. “Florida Legislation Authorizing Pharmacy Technicians to Administer Vaccines Contains Some Surprises.” Akerman. (July 28, 2022). Web.

About the Author: George F. Indest III, J.D., M.P.A., LL.M., is Board Certified by The Florida Bar in Health Law. He is the President and Managing Partner of The Health Law Firm, which has a national practice. Its main office is in the Orlando, Florida, area. The Health Law Firm, 1101 Douglas Ave. Suite 1000, Altamonte Springs, FL 32714, Phone: (407) 331-6620 or toll-free (888) 331-6620.

KeyWords:  administrative hearing defense attorney, Florida Louisiana District of Columbia (D.C.) board of pharmacy defense lawyer, Florida Louisiana District of Columbia (D.C.) board of pharmacy hearing legal representation, Florida Louisiana District of Columbia (D.C.) board of pharmacy investigation legal defense representation, legal representation for pharmaciespharmacy complaint investigation defense attorney, Drug Enforcement Administration (DEAaudit lawyer, Drug Enforcement Administration (DEAsubpoena defnse attorney, Drug Enforcement Administration (DEAsearch warrant defense lawyer, Drug Enforcement Administration (DEA) hearing defense attorneylegal representation in Drug Enforcement Administration (DEA) hearing, Drug Enforcement Administration (DEA) order to show cause (OSC) defense lawyer, legal representation for Drug Enforcement Administration (DEA) order to show cause (OSC) hearing, Florida Louisiana District of Columbia (D.C.) Board of Pharmacy defense representation, legal defense representation for administrative hearingspharmacist defense lawyer for Florida Louisiana District of Columbia (D.C.), Florida Louisiana District of Columbia (D.C.) pharmacist license disciplinary charges defense attorney, reviews of The Health Law Firm, the health law firm, The Health Law Firm attorneyDepartment of Health investigation representation, legal representation for DOH investigations, DOH defense attorneyDOH investigation lawyer

Attorney Positions with The Health Law Firm.  The Health Law Firm is always looking for qualified attorneys interested in the practice of health law. Its main office is in the Orlando, Florida, area. If you are a member of The Florida Bar and are interested, forward a cover letter and your resume to: [email protected] or fax to: (407) 331-3030.

“The Health Law Firm” is a registered fictitious business name of and a registered service mark of The Health Law Firm, P.A., a Florida professional service corporation, since 1999.
Copyright © 2022 The Health Law Firm. All rights reserved.