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Question
Is the registered nurse (RN) allowed to delegate to non-credentialed staff in a daycare, Head Start program, or preschool to perform Clinical Laboratory Improvement Amendments (CLIA) waived COVID-19 testing?
Answer

No. The RN is not allowed to delegate COVID-19 testing to non-credentialed staff in a daycare, Head Start program, or preschool. The laws and rules regarding daycares, Head Start programs, and preschools permit the parent or legal guardian to consent for these entities to provide health care. This permission is known as loco parentis (in place of the parent) and allows these settings to designate staff to act in place of a parent or legal guardian. This also allows the staff to test without an order or standing order from an authorized health care practitioner. The RN may be involved in training staff and providing consultation and guidance regarding the testing. The daycare, Head Start program, or preschool must have the Medical Test Site (MTS) Certification. If a parent or legal guardian does the testing, the site would not be required to have the MTS Certification. The Washington State Board of Nursing (WABON) recommends that early childhood programs consult with the Department of Children, Youth, and Families (DCYF) and their legal counsel.

FAQ Category
Nursing Delegation
Audience