Facility Use of Narcan Subject of Legislative Inquiry

Representative Adam Bernbaum (D-24) recently met with WHCA representatives to discuss the use of Narcan (Naloxone) in skilled nursing facilities. The meeting was prompted by a constituent’s concern that a family member passed away from an apparent opioid overdose in a skilled nursing facility where staff reportedly did not have access to Narcan to administer a potentially life-saving intervention.

The conversation focused on whether facilities are equipped and authorized to stock and administer Narcan. Representative Bernbaum has an interest in understanding the regulatory, clinical, and/or operational barriers that prevent broader access or usage of the medication.

WHCA EVP Elena Madrid provided Rep. Bernbaum with an overview of the CMS requirements related to resident assessment and individualized care planning for residents at risk for overdose, as well as the requirements outlined in F689 related to the need for facility response plans for overdose emergencies. Staff are expected to recognize the signs of substance misuse, monitor at-risk residents, and be prepared to administer naloxone. Facility staff must also be aware of the need for assessment and response related to a resident’s change of condition following medications that place them at risk for adverse effects that may include the need for naloxone regardless of whether there is a diagnosis of substance use disorder. As this may be primarily an education and awareness issue, the WHCA team is committed to working with providers to ensure they understand the regulatory requirements and clinical guidance related to availability and administration of naloxone, and WHCA is also working with the Department of Social and Health Services (DSHS) on a Dear Provider Letter, which will outline the relevant requirements and clarify expectations for skilled nursing providers.

If you have questions about the use of naloxone, please contact Elena Madrid (for skilled nursing providers) and Vicki McNealley (for assisted living providers).

Resources

WHCA’s July 25 Survey and Regulatory Update includes a suggested rescue protocol for opioid use.

WABON advisory opinion on the storage and administration of naloxone