Sending Medications with Residents

It is common for assisted living residents to leave the facility to attend community events, go out to a restaurant with friends or family, or even go on a weekend trip. Given the overwhelming number of residents who take more than a handful of medications each day, it stands to reason that the facility must have a plan in place to safely and legally send necessary medications with residents when they temporarily leave the setting.

The complexity of Washington’s regulations on medication management tends to confuse this issue. One must search the assisted living regulations, only to be sent to the pharmacy law and pharmacy regulations.

RCW 69.41, Washington’s law on prescription drugs, defines the term “dispense” as “the interpretation of a prescription or order for a legend drug and, pursuant to that prescription or order, the proper selection, measuring, compounding, labeling, or packaging necessary to prepare that prescription or order for delivery.” Only a practitioner may dispense a medication; the same law defines the term “practitioner” to include a physician, dentist, podiatrist, surgeon, optometrist, physician assistant, as well as a pharmacist, LPN, and RN (in addition to a few other professionals not typically working in an assisted living facility).

Caregivers who assist with or administer medications cannot dispense medications; this action is outside the scope of practice for a “nonpractitioner.” Since dispensing includes packaging and labeling medications, this means a caregiver cannot remove a medication from its original pharmacy-prepared or manufacturer-prepared labeled container into another package for later use. Furthermore, the medication assistance WACs (currently in emergency status and not easily located on the internet) clearly states that a nonpractitioner must prepare medications just prior to delivery; this WAC, too, disallows a caregiver from preparing a resident’s medications to take later.

This leaves a few limited options that facility staff can implement to ensure the resident does not miss necessary medications. Some of those options include:

· NURSE PREPARATION. Because a licensed nurse is considered a practitioner, s/he can legally move medications from their original containers into an envelope or other similar package for easy transport. These “to go” medication packages do require some additional documentation/directions written on the package per WAC 388-78A-2280.

· PHARMACY PREPARATION. If a resident is planning a vacation or some other extended leave, the pharmacy may be able to package medications in a more user-friendly format that allows the resident to take just the number of medications needed for the trip.

· SEEK ALTERNATIVE TIMES. In rare occasions and in collaboration with the prescriber, a resident might be able to take certain medications before leaving the facility (earlier than prescribed) or upon returning (later than prescribed). This arrangement should be in collaboration with the medication system supervisor, the resident, and the prescriber and it should be documented in the resident’s record.

· ALL RELEVANT MEDICATIONS SENT. The caregivers can send each medication, in its entire packaging, with the resident. While seemingly inconvenient, some instructions may be needed to educate the resident or family/friends on how and when the medications must be taken, and any documentation of meds taken that might be needed upon returning to the facility.

Regardless of which methods are used, the facility should have a policy and procedure or other written process for medication staff to follow each time a resident, who requires assistance or administration with medications, leaves the facility.