Requirements for Administering
Medications in Residential Care Apartment Complexes (RCACs)
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DATE: September 25, 2002 DSL-BQA-02-018
TO: Residential Care Apartment Complexes RCAC - 05
FROM: Kevin Coughlin, Chief, Assisted Living Section
via: Susan Schroeder, Director, Bureau of Quality Assurance
As a result of findings during recent certification visits of RCACs,
the Bureau is issuing this bulletin to clarify
the requirements for administering medications to residents in a
Residential Care Apartment Complex setting. The following provisions apply
to medication administration:
"Medication administration" means giving or assisting
tenants in taking prescription and nonprescription medications in the
correct dosage, at the proper time and in the specified manner. Wis.
Admin. Code § HFS 89.13(21) (exit DHFS).
"Medication management" means oversight by a nurse,
pharmacist or other health care professional to minimize risks associated
with use of medications. Medication management includes proper storage of
medications; preparation of a medication organization or reminder systems;
assessment of the effectiveness of medications; monitoring for side
effects, negative reactions, and drug interactions; and delegation and
supervision of medication administration. Wis.
Admin. Code § HFS 89.13(22) (exit DHFS).
"Nursing services" means nursing procedures, excluding
personal services, which, according to the provisions of ch. 441, Stats.,
the nurse practice act, must be performed by a registered nurse or as a
delegated act under the supervision of a registered nurse.
Wis. Admin. Code § HFS 89.13(24) (exit DHFS), see also Wis.
Admin. Code chs. N 6 and N 7 (exit DHFS).
An RCAC must be able to provide the minimum required nursing services,
which includes health monitoring, medication administration, and
medication management, to any tenant who needs or develops a need for
nursing services, either directly or under contract. See Wis.
Admin. Code § HFS 89.23 (exit DHFS).
Nursing services and supervision of delegated nursing services shall be
provided consistent with the standards contained in the Wisconsin nurse
practice act. Medication administration and medication management shall be
performed by or, as a delegated task, under the supervision of a nurse or
pharmacist. Wis.
Admin. Code § HFS 89.23(4)(a)2 (exit DHFS).
Based on the above code provisions, if an RCAC is administering or
assisting residents with administering medications, the facility must
have a registered nurse (RN) employed or under contract, who either
administers medications or assists residents with administering
medications, or delegates and supervises medication administration. An RN
must comply with the Wisconsin nurse practice act when delegating and
supervising medication administration. Although licensed practical nurses
(LPNs) may manage and direct staff in some aspects of nursing care, only
RNs, pharmacists or physicians can delegate medication administration to
unlicensed RCAC caregiver staff. The Standards of Practice for
Registered Nurses is contained in Wis.
Admin. Code § N 6.03(3) (exit DHFS). In the supervision and direction
of delegated nursing acts, an RN shall:
- Delegate tasks commensurate with educational preparation and
demonstrated abilities of the person supervised;
- Provide direction and assistance to those supervised;
- Observe and monitor the activities of those supervised; and
- Evaluate the effectiveness of acts performed under supervision.
The RN must also be able "to coordinate, direct and inspect the
practice of another" on a regular basis under general supervision
whenever any activity is delegated to another person. Wis. Admin. Code §
N 6.02(7). Because delegation must be to "a person," there
should be clear and specific documentation in the facility’s policies
and procedures to show who is working under the RN’s license. BQA
assisted living survey staff will monitor compliance by observing a
facility’s medication management and administration activities,
interviewing the RN and the staff working under the RN’s license, and
reviewing relevant documentation. Examples of relevant documentation
includes the following:
-
Policy regarding the delegation of medication
administration to include specific RCAC staff who have accepted
delegated nursing acts from a specific RN; how direction and
assistance are provided to those supervised; and how monitoring and
evaluation of delegated acts are achieved.
-
Documentation addressing education and demonstrated
skills of the individual(s) who have accepted delegated nursing acts
from a specific RN.
-
Documentation of periodic review of the delegated acts
by the supervising RN.
Furthermore, if an RN is not in the building or on-site during periods
of delegation, there needs to be a system in place to assure the RN is
available to provide direction and assistance to those supervised.
In addition, if an RN is delegating medication administration to
unlicensed RCAC caregivers, this information must be addressed in the
service agreement with the resident according to Wis.
Admin. Code § HFS 89.27(3)(c) (exit DHFS). BQA also encourages the RN to inform
the physicians who provide medical care for residents that unlicensed
caregivers are administering medications for their patients.
Please share this information with your Registered Nurse and all staff
who are functioning under delegation. If you have any questions, please
contact the appropriate regional survey
office at [click on the link]:
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