67.5(2) Policies on Medication Procedures

During the last Assisted Living Rule Review, the registration with the Iowa board of pharmacy was reviewed. The next rule in sequential order includes 67.5(2) which states that each program shall follow its own written medication policy, which shall include the following:

• The program shall not prohibit a tenant from self-administering medications.
• A tenant shall self-administer medications unless:
  • The tenant or the tenant’s legal representative delegates in the occupancy agreement or a signed service plan any portion of medication setup to the program.
  • The tenant delegates medication setup to someone other than the program.
  • The program assumes partial control of medication setup at the direction of the tenant. The medication plan shall not be implemented by the program unless the program’s registered nurse deems it appropriate under applicable requirements (including nurse delegation). The program’s RN must agree to the medication plan.
  • A tenant shall keep medications in their possession unless the tenant or legal representative delegates in the occupancy agreement or signed service plan partial or complete control of medications to the program. The service plan shall include the tenant’s choice related to storage.
  • When a tenant has delegated medication administration to the program, the program shall maintain a list of the tenant’s medications. If the tenant self-administers, the tenant may choose to maintain a list of medications in their apartment or to disclose a current list of medications to the program for the purpose of emergency response. If the tenant discloses a list of medication, the tenant remains responsible for the accuracy of the list.
  • When medication setup is delegated to the program by the tenant, staff via nurse delegation may transfer medications from the original prescription containers or unit dosing into medication reminder boxes or cups.

This process is important to understand as AL programs are opposite of nursing home settings. At a baseline the tenant self-administers medications and only when it is delegated does the program have any control over the tenant’s medications. Tenant’s may go to the ER or complete an office visit and change medications without the program knowing. Which ever method is delegated is what should be included in the service plan, even if the tenant delegates medication setup to a third party such as their family or a friend.

Programs should review their policy to ensure that it reflects that a tenant self-administers medications at baseline and the requirements for maintaining lists of tenants medications. If you are part of a CCRC setting and have a different level of care as a backup emergency response it may be worthwhile to review the AL processes with leadership so they understand that the medication list may not be accurate depending on what the tenant has delegated to the program.

There are additional procedures related to medications that will be reviewed in June to finish the medication section of the AL rules.