When the federal public health emergency expired on May 11, 2023, so did the Washington state standing order that authorized the administration of POC testing by non-medical staff. This means that, moving forward, only registered nurses (RNs), RN-delegated staff, or RN-directed licensed practical nurses (LPNs) are permitted under state law to perform POC tests onsite.

This is an abrupt change to the policy that has governed school testing over the past several years, and schools understandably have a lot of concerns.

During the Learning Network event last week, schools sent us questions that cover a range of topics, like: 

• Nursing scope of practice 
• Nurse delegation of testing activities
• MTS licenses (CLIA waivers) 
• Testing supplies
• K-12 guidance 
• DOH communications
• Transitioning to an OTC-only model

On the Q&A page, we have listed all of your questions by topic and tried to answer each as thoroughly as possible. We hope these responses will help you and your team determine the best path forward for your testing program.

Here are some key takeaways from the Q&As:

• The Washington state standing order that authorized non-medical staff to perform point-of-care (POC) testing expired with the end of the federal public health emergency on May 11, 2023. 
• Moving forward, only registered nurses (RNs), RN-delegated staff, or RN-directed licensed practical nurses (LPNs) are permitted under state law to perform POC tests onsite.
• RNs can delegate the administration of POC testing to non-medical school staff or direct LPNs to perform POC testing. (See Q&A section: Nursing scope of practice & nurse delegation for more information.).  
• The Nursing Care Quality Assurance Commission (NCQAC) has released a letter that provides clarification around nursing practice authority in school settings for delegation and administration of COVID-19 tests:  Authority of Registered Nurses to Administer and Delegate COVID-19 CLIA-Waived Tests in School Settings.
• RNs interested in delegating POC testing to non-medical staff should follow guidance in the NCQAC Advisory Opinion 15.01: Registered Nurse Delegation in School Settings: K-12 Grades, Public and Private.
• Questions about RN delegation to non-medical staff or RN direction to LPNs should be sent to the NCQAC at NursingPractice@doh.wa.gov. 
• MTS licenses (CLIA waivers) expire on June 30, 2023, for all L2R schools. If you intend to offer POC testing after June 2023, you MUST renew your MTS license. An MTS license is not required for the distribution of over the counter (OTC) tests like iHealth.
• All PCR testing through Learn to Return has been paused until further notice. 
• For schools that do not have an RN, the best option may be to transition to an over the counter (OTC) testing model and sunset POC testing. Here are some tips about transitioning to an OTC-only model.

Washington State Department of Health (DOH) is offering at-home COVID-19 rapid antigen tests for schools, early childhood education centers, and groups that serve PreK-12 age children and youth to distribute this summer. This opportunity is for camps and extracurricular organizations— recreational or educational—that serve children and youth during the summer months, such as club sports, outdoor education centers, etc. 

Get started with ordering here.

Questions? Reach out to schools@healthcommonsproject.org.