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    Becoming a Point of Dispensing for COVID-19 Vaccines

    Strategize a sound plan to make storing and providing a vaccine easier.

    Once COVID-19 vaccines created under Operation Warp Speed are given approval for wide distribution, colleges and universities in some communities may be asked to vaccinate their campus populations. Following a request from your local or state Department of Health your institution may decide to conduct a mass vaccination event for your campus community.

    Before finalizing your decision, consult with counsel to understand your institution’s legal responsibilities and potential liability. While the Public Readiness and Emergency Preparedness ( PREP) Act, along with the Health and Human Services Public Declaration, may provide immunity for those distributing and administering vaccines, it is important to understand the application of the Act to the current COVID-19 pandemic and vaccination. Furthermore, state law interaction with the PREP Act is something to discuss with counsel.

    Memorialize the agreement to serve as a vaccine dispensing point 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 vaccine supplier as possible, to provide your institution with an additional level of protection.

    Planning to Become a Point of Dispensing

    A large-scale vaccine distribution event takes planning and coordination. After deciding you will serve as a vaccine point of dispensing (POD), create a POD plan such as the one at Purdue University. 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 serve as a POD. Identify a vaccination site (field house, auditorium, large fields if vaccination will be outdoors). Choose a location appropriate for the size of your vaccination event.
    • Site details. For example, will protection from the elements be available as people wait? Also consider facility access points and internal traffic flow. Identify areas for vaccine and supply storage, including ways to keep these items temperature controlled and secure.
    • Supplies. Identify and order necessary supplies for vaccine administration and begin sourcing the needed quantities. Determine where these supplies will be secured prior to POD 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. Staff appropriate personnel available 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). 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.


    After completing your POD 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 prior to their participation.

    Additional Resources

    Centers for Disease Control and Prevention (CDC): COVID-19 Vaccination Program Interim Playbook
    CDC: Closed Points of Dispensing Toolkit
    CDC: COVID-19 Vaccination Program Provider Requirements and Support
    Orange County California: POD Planning Resources
    American College Heath Association (ACHA): Mass Vaccination Clinic Guidance and Resources
    Fisher Phillips: What Schools Should Know Before Setting Up On-Campus COVID-19 Vaccine Clinics

    By Heather A. Salko, senior risk management counsel