Guidance to NAFV Members in Efforts to Aid with the Administering of the COVID-19 Vaccine

The National Association of Federal Veterinarians (NAFV) has been made aware that the Federal Emergency Management Agency (FEMA) is requesting support from federal veterinary medical offices (VMOs) to administer the COVID-19 vaccination. While it is not yet clear as to how these assets would be used, in logistics, support to human medical professionals, or administering the vaccine to humans directly, it is worth looking at the possibilities and ramifications.  

Federal veterinarians are positioned differently than are their non-federal colleagues. NAFV supports federal veterinarians being deployed to administer vaccinations to humans with the guidance below. 

Considerations for those who seek to provide support in administering the COVID-19 vaccine: 

1. Veterinarians are public health professionals, and have medical expertise not limited to non-humans. 
2. If accepting this responsibility, authorization must be provided to them in writing stating that this assignment is official duty and within the scope of the individual's employment. It should not include anything about voluntary duty regardless of how the assignment was initiated. 
3. This would remove individual liability insurance and the Federal Tort Claims Act would be applied. No "constitutional tort" exemption about individual liability would apply. If any problem does arise Office of General Council (OGC) and Department of Justice (DOJ) would step in. 
4. The same is true of the American Veterinary Medical Association (AVMA), Federal Employee Defense Services (FEDS) or other professional liability insurance. None would apply or be necessary. 
5. Veterinary licenses would be irrelevant as none authorize treating humans. 
6. Participants must receive and document specific instruction about the injection process, which would include the location, the injection procedure, depth and other required procedures. 
7. NAFV would like to point out that there are veterinarians in non-veterinary positions according to position title. These individuals should be utilized if it can be established that they are veterinarians. 
8. NAFV opposes non-veterinarians to administer these vaccines, other than recognized human practitioners. NAFV's position is that only recognized medical individuals should do so.   
9. Any veterinarian assisting in COVID-19 vaccinations, must make sure there is a medically certified human health professional on hand to treat anyone who may have a bad reaction to the vaccine. A veterinarian may be in charge, like an incident commander, but cannot exceed what is specifically authorized. 

In addition, NAFV plans to seek guidance from agency leadership related to how those who are deployed to such efforts can be prioritized for the vaccine themselves. We will share more information on that as it develops.
With any questions, please reach out to the NAFV National office at nafv@nafv.org or 202-223-4878.