August 27 2026 | Medication Management Citations Top-Of-Mind for DSHS

In a recent meeting, Residential Care Services (RCS) leadership team members shared concerns with WHCA staff regarding the continued uptick of medication-related citations in assisted living. During the meeting, WHCA staff emphasized that the vast majority of issues regarding medication system development and implementation are complex and require careful consideration to determine long term fixes.

The second-most cited WAC so far in 2026 is 388-78A-2210 Medication Services; this fact is not new. Medication management citations have been situated in the top five WACs cited year after year. The subsection of most concern is (1)(b) and it reads:

“An assisted living facility providing medication service, either directly or indirectly, must develop and implement systems that support and promote safe medication service for each resident.”

This subsection can apply to so many scenarios where medications are not delivered on time or not given at all. Medication errors could fall into this category, as could system breakdowns relating to storage, documentation, following medication parameter instructions, or nurse delegation.

No matter the reasons for the citation, the findings remain: residents in assisted living take a lot of medications each day, and systems are absent or haphazardly applied when it comes to safe medication ordering, delivery, storage, documentation, and/or follow-up.

Weak or poorly maintained medication systems can prove costly to residents and facilities. Medication systems are core to resident safety, and systems failures pose significant risk of adverse events and negative resident outcomes. In addition, medication system breakdowns increase a facility’s risk management liabilities.

Medication system violations can be cited for even one error that might affect only one resident. Citations associated with medication system breakdowns often result in swift enforcement action including but not limited to stop placement of admission orders and/or conditions on a license.

As a regulatory consultant and registered nurse, I stand by the idea that medication systems development and implementation in assisted living do not require nurse management. Some of the greatest assisted livings, with the smoothest-operating medication systems, are led by skilled, talented, and knowledgeable caregivers who have made it their life’s work to ensure medication safety. The key is capturing a caregiver’s passion and giving them the tools to develop into strong medication management leaders within the organization.

Self-regulation is much more favorable when compared to agency regulation. WHCA nor likely its members are interested in RCS outlining in law and rule the specific training, certification, staffing, and/or auditing expectations related to medication systems in our care settings.  And yet, during the meeting mentioned earlier in this article, the insinuation for such remedies was palpable.

Assisted living facilities collectively hold the opportunities to strengthen and standardize medication management policies and procedures, staff training, routine system reviews and audits to safely serve residents. All of these efforts can be accomplished without additional and burdensome regulations.

While WHCA can help in this endeavor, assisted living facility and corporate leadership must prioritize medication safety systems to ensure consistent medication delivery based on prescriber orders. Should you have ideas on how to best address ways to minimize medication system citations, and you believe WHCA’s reach could aid in moving ideas to reality, please email me at the WHCA office.