Nothing in Title 22 authorizes caregivers to directly administer medications; this task is reserved for appropriately skilled professionals. Most facilities do not retain appropriately skilled professionals, since Title 22 does not require it. Therefore, it is imperative consumers clarify with facilities what the facility means when it advertises "Medication Management Services"; does the facility have a nurse on staff to oversee the handling of both prescription and non-prescription drugs?
To directly administer medications (per CARR's recent discussions with CCLD's Sacramento office), is to place the medication in a resident's mouth or, in the case of injections, to fill a syringe and/or inject a resident with medication. Unlicensed (not appropriately skilled professional) caregivers are not allowed to administer medications. They are allowed to prepare medications (i.e. dispense and pour). This preparation is what is meant by "assist with self-administration" in the regulations. Facilities that provide assistance with medications are responsible for accurately logging dosage and maintaining medical records, and for prompt communications with resident's physician.
When considering placement, the consumer should consider the ability of the resident to self-administer medications. Matching the resident's ability to the competency and capabilities of the facility is critical to be avoid medication errors.
Provided here is Title 22's (§ 87455 & § 87465) guidance and requirements for medication assistance.
RCFEs are allowed to accept or retain:
- Persons capable of administering their own medications,
- Persons who because of forgetfulness or physical limitations need only be reminded or to be assisted to take medication usually prescribed for self-administration,
- Persons receiving needed medical care from a visiting nurse.
1) Staff designated by the licensee may assist persons with self-administration as needed. Assistance shall be limited to the following:
- Medications usually prescribed for self-administration which have been authorized by the person's physician.
- Medications during an illness determined by a physician to be temporary or minor.
- Assistance required because of tremor, failing eyesight, and similar conditions.
- Assistance with self-administration does not include forcing a resident to take medication, hiding or camouflaging medications in other substances without the resident's knowledge and consent, or otherwise infringing upon a resident's rights to refuse medications.
2) Staff shall be permitted to assist if:
- the resident's physician has stated in writing that the resident is able to determine and communicate his/her need for a prescription or non-prescription PRN ("as needed") medication.
- the resident's physician has stated in writing that the resident is unable to determine his/her own need for PRN medications but can communicate his/her symptoms clearly. Provided there is written direction from the physician, on a prescription blank, specifying all administering information; the medication is given according to the physician's directions; a record of each dose is maintained in the resident's record (including the date and time given, the dosage, and the resident's response).
- the resident is unable to determine his/her own need for PRN medications, and is unable to communicate symptoms clearly. Provided staff contact the resident's physician prior to each dose, describe resident's symptoms, and receive direction to assist the resident in self-administering that dose of medication; the date and time of each contact with the physician, the physicians directions, are documented and maintained in resident's record; the date and time the PRN med was taken, dosage, and resident's response recorded.
3) For every PRN medication for which the licensee provides assistance there shall be a signed, dated written order from a physician on a prescription blank maintained in the residents file and a label on medication (both containing specific symptoms to indicate need, exact dosage, minimum number of hours between dosage and maximum number of doses allowed in 24-hour period).
In conversations between CCLD's Duty Worker, and CARR in May 2011, to administer PRN ("as needed") medications, a physician must be contacted prior to each dosage. Medications administered daily must be given according to the physician's directions which must be reflected on the prescription bottle and in the resident's file (§87465 (c)(2)). Records of daily medications must be maintained as well.