AGING AND DISABILITY SERVICES ADMINISTRATION

June 9, 2003

ADSA: BH #2003-014
USE OF MEDICATION ORGANIZERS

Dear Boarding Home Provider:

You were recently sent a letter ADSA: BH #2003-005 regarding Department of Health Advisory Opinions on Medication Assistance and Filling Medication Organizers. One of the enclosures was the Washington State Nursing Care Quality Assurance Commission Position Statement on Medication Organizer Devices in Community Based Long Term Care and Private Homes: Roles for RNs and LPNs (enclosed).

This position statement indicated that it was within a nurse’s scope of practice to fill customized patient medication packages (i.e. “Medisets”) under certain conditions.
The position statement must be considered in the context of the current boarding home licensing rules. Washington Administrative Code (WAC) 388-78A-300(7)(c)(i) reads:

(7) The licensee shall assure staff follow the written policies and procedures
for each medication service category provided in the boarding home
including:
(c) Storing resident medications:
(i) In original containers with pharmacist-prepared or manufacturer's label;

WAC 388-78A-(7)(c)(i) has been, and continues to be interpreted as prohibiting medications under the boarding home’s control from being stored in medisets or other containers that are not the original medication container with the manufacturer’s label, or a container filled and labeled by a pharmacist.

In the past, medisets have been accepted for use in a boarding home only when:

• The medisets have been filled and labeled by a pharmacist, or
• A resident was independent in taking his or her own medications without any assistance from the boarding home (including filling the mediset), and:
  • The resident or the resident’s family filled the mediset; and
  • The boarding home was not responsible for storing or securing the medications stored in the mediset.

In light of the Nursing Care Quality Assurance Commission’s position statement to allow nurses to fill medisets, Residential Care Services has slightly modified its policy on the use of medisets. The following policy regarding the use of medisets is effective immediately:

1. Boarding homes must ensure no staff person other than a nurse fills medication
   organizers for residents. A nurse may fill a medication organizer for a resident only
   when:
   1. The resident is knowledgeable of the medications in the medication organizer
      that have been prescribed for him or her; and
   2. The resident is totally independent with self-administration of medications when
      using a medication organizer, except for the physical assistance required to fill
      the medication organizer, or the resident can safely direct others to administer
      his or her medications; and
   3. Staff persons have no further responsibility for:
      • Storing the resident's medication organizer; or
      • Providing any additional medication assistance to the resident regarding the medications in the medication organizer beyond filling the medication organizer; or
      • Providing medication administration services to the resident regarding the medications in the organizer.
   4. The nurse labels the medication organizer with a label that clearly identifies:
      • The name of the resident,
      • The name of the medications in the organizer, and
      • The frequency of the dosage.
2. Consistent with subsections (1) and (3) of this section, the boarding home must not use a medication organizer for a resident, filled by anyone other than a licensed pharmacy, any time the boarding home is:
   1. Involved in the storing the resident's medication organizer;
   2. Providing medication assistance to the resident for the medications in the organizer; or
   3. Providing medication administration services to the resident for the medications in the organizer.
3. Residents may use medication organizers only when they store and secure their own medications and are capable of either:
   1. Independently self-administering the medications in the medication organizer, or
   2. Safely directing others to administer their medications.

Contact Denny McKee, Program Manager, at (360) 725-2590 if you have any questions regarding this policy.

Sincerely,

Patricia K. Lashway, Director
Residential Care Services

Enclosure