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Medication Management in Residential Care Facilities/Assisted Living
About 14 years ago, the state of Nevada crafted law and regulations that allowed staff in a Residential Care/Assisted Living Facility (RCF/ALF) to assist residents with their daily medication. Prior to that time, it was assumed that if a resident could not manage their own medications, perhaps they should be in a skilled nursing facility. It actually took an action of the legislature, and a group effort of the Board of Nursing, Board of Pharmacy, Bureau of Licensure and Certification (Nevada State Health Division), and residential care industry professionals to craft that law and subsequent regulations to establish procedures and protocols for such assistance or “administration” of medication.
Over the past 14 years, several modifications have occurred, some of which prove confusing to the family members as well as the senior residing in the facility. However, the purpose has been to assure that each senior residing in a residential care/assisted living facility has the utmost protection with regard to medication management.
Initially, guidelines were established for the receipt, storage and administration of medications. Documentation in the form of a Medication Administration Record (MAR) is required, and medication must be given as prescribed by the physician for routine or scheduled medications and those given “as needed” (usually for pain management).
Additional criteria have been established that required caregivers assisting with the administration of medication attend a state approved training and pass a state approved testing process. Subsequent regulations were adopted requiring those caregivers to have training updates every 3 years, and pass an additional exam. Recently, a newly developed recertification exam has been developed by the state, and will be implemented in January of 2009.
Regulations further require that, at least every 6 months, a pharmacist, physician or nurse (who does not have financial involvement with the facility) review for accurateness and appropriateness the medication regime including over the counter medications and supplements.
Again, the whole intent is to assure that there is no situation that would endanger the health or well-being of the resident.
The most confusing item is in the language: “an over the counter medication (OTC) or dietary supplement may be given to a resident only if the resident's physician has approved the medication or supplement in writing…and must be administered in accordance with the written instructions of the physician.” So frequently, when an individual moves to a facility from home, they have OTC medications or supplements they have been taking at will. When told by the facility they must have physician approval to have these convenience items, often the resident, family and facility become frustrated. The whole rationale is to assure that protective supervision occurs and that OTC medication or supplement will not have an adverse effect or be contraindicated with prescription medications the resident might be taking.
The biggest challenge for the resident, family members and facility is assuring that all medications ordered have a written order from the physician (prescription) in the file of the resident at the facility. Oftentimes, family will take the resident to a medical appointment, receive a prescription, take it to the pharmacy and have it filled. Shortly thereafter, the facility will tell the resident or family member that they need a copy of the order for the file to meet regulatory requirements. If the resident receives mail order medications or medications from a governmental entity, such as the VA, a copy of the order may not be available and the facility will be in violation of a regulatory requirement. It is critical to obtain a copy of the written order from the physician to provide to the facility.
In summary, Residential Care/Assisted Living Facilities can assist their residents with medication management, but such assistance must comply with the regulations they operate under. It is to the benefit of the family members, resident and facility to assure all parties understand those regulations. ( NAC 449.2742- Nac 449.2748)
I welcome your feedback and opinions. You may e-mail me at: wendy.simons.consult@gmail.com