Hot Topic of Medication
Management in Residential Care/Assisted Living Facilities
By Wendy Simons
it interesting how things roll along smoothly for years then all chaos
the past 18 months, 5% of the licensed larger Residential Care/Assisted
Living facilities (RCF/AL) in the state have experienced significant
issues with regard to medication management and 50% of the smaller RCF/group
homes have had similar issues. Some of these issues have resulted in
fines in excess of $100,000 by the licensing entity, the Bureau of
Health Care Quality and Compliance, most specifically for “failure to
administer medication as prescribed”. But first, a bit of history might
be in order.
16 years ago, the state of Nevada crafted law and regulations that
allowed staff in a Residential Care/Assisted Living Facility (RCF/ALF)
to assist residents with their daily medication. Prior to that time, it
was assumed that if a resident could not manage their own medications,
perhaps they should be in a skilled nursing facility. It actually took
an action of the legislature, and a group effort of the Board of
Nursing, Board of Pharmacy, Bureau of Licensure and Certification (of
the Nevada State Health Division) and residential care industry
professionals, to craft that law and subsequent regulations to establish
procedures and protocols for such assistance or “administration” of
the past 16 years, several modifications have occurred, some of which
prove confusing to the family members as well as the senior residing in
the facility. However, the purpose has been to assure that each senior
residing in a residential care/assisted living facility has the utmost
protection with regard to medication management and assistance.
Initially, guidelines were established for the receipt, storage and
administration of medications. Documentation in the form of a Medication
Administration Record (MAR) is required and medication must be given as
prescribed by the physician for routine or scheduled medications and
those given “as needed or PRN” (usually for pain management).
Additional criteria have been established that required caregivers
assisting with the administration of medication attend a state approved
training and pass a state approved testing process. Subsequent
regulations were adopted requiring those caregivers to have training
updates every 3 years and pass an additional state approved exam. A
newly developed recertification exam was developed by the state and was
implemented in January of 2009.
let’s return back to the current issues. Standards and regulations
must be administered as prescribed by the resident’s physician.
This also includes over the counter (OTC) and supplements.
the breakdown in this process that is causing all the fuss, media
coverage and fines? The top issues are:
- Facilities are
failing to obtain refills for medication prior to the resident’s
running out; therefore the medication is not available to give.
- Facilities are not
securing physician approvals in a timely manner to assure refills
are obtained before the resident runs out.
- Pharmacies report
insurance companies are not authorizing refills in a timely manner.
- Family members or
responsible parties are refusing to pay for costly medication and
again, medication is not available to give.
- Family members are
not bringing the proper medication and OTC/Supplements as written in
the physician orders (Example: “Calcium with vitamin D” may be the
order and family brings plain “Calcium”).
Facility operators and caregivers who
assist with medication are not being diligent in their systems
management to properly give or document medication administration.
regulatory oversight perspective, when a facility is cited at time of
survey or following a complaint investigation, the facility is given a
clear understanding of the regulatory deficiency. It responds with a
plan of correction that it has taken steps to correct the problem and
how to prevent it occurring in the future. When the regulatory authority
( HCQC) goes back to follow-up and finds that the problem still exists,
fines or sanctions may be imposed.
has happened in the cases that have become newsworthy? The facilities,
their ownership, management and staff just “didn’t get it” and failed to
correct the problem quickly. In some cases in the Las Vegas area, the
HCQC was able to substantiate that harm had occurred to a few residents
due to the failure to give medications as prescribed and tougher
sanctions were imposed.
must remain mindful that one bad story shakes public confidence and all
other facilities come under scrutiny. Facilities that betray that
confidence have already suffered financial penalties and long term
damage to their reputations, but the fall out of bad practices has an
effect on other providers in the industry.
you with this final thought. There is tremendous benefit to our seniors
who settle happily into a supportive environment with caring staff. It
goes without saying that many facilities operate with exceptional
dedication to their seniors and minimal issues; but sadly, bad news
casts doubt. (Look at Toyota and their recent news, great company, now
discover the need to have a loved one in a Residential Care/Assisted
Living facility, just ask the tough questions, continue to be on top of
issues of concern, advocate for the well being of that person, and be a
partner in the care and services planning for that person. It takes a
team (family, doctor, care facility, pharmacy) to assure that medication
management and administration remain successful.