June 20 2025 | Medication Systems Evaluation During Licensing Visits

Medication management in assisted living continues to rack up deficiencies from state licensors and complaint investigators. With residents taking more prescription and over-the-counter medications each day, it’s no wonder Statement of Deficiencies reports continue to feature medication-related citations.

Historically, medication-related citations centered on the facility staff’s knowledge of the differences between medication assistance and administration. For example, licensors may have discovered medication staff administering medications when they were not delegated to do so, or assisting with medications for a resident who was assessed as independent with medication management.

The reasons for medication citations, for the most part, have shifted toward staff’s knowledge of the facility’s systems and residents’ needs (or more specifically, the lack of staff’s knowledge of these two issues). The licensing teams’ approaches have also shifted, from observing medication delivery and inquiring for the purposes of clarification, to asking questions first to see what level of knowledge and experience the facility staff has with the facility’s medication systems and residents.

This shift in focus from observation-inquiry to question-gotcha has occurred at the DSHS training level and without notice to member associations including WHCA. A new Assisted Living Facility Medication Observation Worksheet, Attachment S, was published in April 2025 in the DSHS Standard Operating Procedures (SOP) for assisted living licensing processes. This attachment, which is highlighted in the SOP as an optional tool the licensors may use, includes observation prompts for licensors that are within the standard historical expectations for a medication pass audit. The questions to ask, however, are new and could potentially cause confusion or be misunderstood by facility medication staff.

WHCA has taken issue with this new form and the potential misuse of its application during a licensing inspection. WHCA staff has met with DSHS leadership to share concerns about the form and its potential use during an inspection; we will keep you updated on the outcome of this collaboration. In the meantime, consider using the questions found in Attachment S as a training opportunity to prepare facility medication staff for the DSHS licensing visit.

For questions about medication systems in assisted living, email Vicki McNealley or call her at 360-352-3304 extension 107.