Medication storage and disposal can very quickly become a compliance issue, causing the facility a citation with the potential of putting resident health at risk. Now is a good time to review how your facility manages the storage of current, discontinued and expired medications, as well as medication disposals.
Concerning resident rights and facility procedures, 58A-5.0182(6) (d) states that the facility must have a written statement of its house rules and procedures that must be included in the admission package provided pursuant to rule 58A-5.0181, F.A.C. The rules and procedures must, at a minimum, address the facility’s policies regarding resident responsibilities, which includes medication storage.
Facility reviews should begin with the admission packet and the policy related to medication storage to ensure compliance.
In 58A-5.0185(6) FAC, medication storage and disposal are described. The intent is to allow residents to be as independent as possible while keeping in mind there are multiple residents with individual needs and safety concerns. Residents may keep their medications, both prescription and over-the- counter, in their possession both on and off the facility premises. Residents may also store their medication in their rooms or apartments if either the room is kept locked when residents are absent, or the medication is stored in a secure place that is out of sight of other residents.
The term “medications” refers to over-the-counter (OTC) products and prescription medications. The term OTC includes, but is not limited to, OTC medications, vitamins, nutritional supplements and nutraceuticals. These are referred to as OTC products, which can be sold without a prescription (the subject of CBD oil and medical marijuana is for another day).
Both prescription and over-the-counter medications for residents must be centrally stored if:
- The facility administers the medication.
- The resident requests central storage. The facility must maintain a list of all medications being stored with this type request.
- The medication is determined and documented by the health care provider to be hazardous if kept in the personal possession of the person for whom it is prescribed.
- The resident fails to maintain the medication in a safe manner.
- The facility determines that, because of physical arrangements and the conditions or habits of residents, the personal possession of medication by a resident poses a safety hazard to other residents.
- The facility’s rules and regulations require central storage of medication and that policy has been provided to the resident before admission as required in rule 58A-5.0181, F.A.C.
Regulations do not specifically say what type of storage container must be used for centrally stored medications. Rather they state that the medications must be stored in a locked cabinet, locked cart, or other locked storage receptacle, room, or area at all times. Wherever you choose to store the medications, consider whether the location is free of dampness or extreme temperatures. Remember, medications that need refrigeration must be locked as well. Surveyors will be looking for where drugs are stored and note whether the medication cabinet, room, medication cart or other area is locked, and the key is out of sight.
During the facility tour, the surveyors will observe whether there are drugs visible on counter tops, dressers, nightstands, etc. If medications are observed during the tour, this must be further explored. During one survey, an administrator was touring a resident’s room with the surveyor and a pill was laying on the nightstand. This resident was quite capable of self- administration and clearly informed the surveyor that she lays the medication out as a reminder to take before she leaves for her meal. It was almost mealtime. The surveyor was comfortable that the resident was capable and that this was appropriate. If the resident had not shown this clarity, the surveyor would have brought this to the attention of the administrator.
If medications are not kept secured in the resident’s room or apartment and the resident requests facility courtesy storage, those medications must be centrally stored. Keeping medications separated from other resident medications must be maintained as part of each storage option.
There must be an individual trained to assist with medications at all times and with the keys or codes for easy access to the medications. There cannot be a time when medications are not available to residents as ordered.
Medications that have been discontinued but have not expired must be returned to the resident or the resident’s representative, as appropriate, or may be centrally stored by the facility for future use by the resident at the resident’s request. If centrally stored by the facility, the discontinued medication must be stored separately from medication in current use, and the area in which it is stored must be marked “discontinued medication.” These medications may be reused if prescribed by the resident’s health care provider.
When a resident’s stay in the facility has ended, the administrator must return all medications to the resident, the resident’s family, or the resident’s guardian unless otherwise prohibited by law. If, after notification and waiting at least 15 days, the resident’s medications are still at the facility, the medications are considered abandoned and may be disposed. When the 15 days have past, medications that have been abandoned or have expired must be disposed of within 30 days of being determined abandoned or expired and the disposal must be documented. The medication may be taken to a pharmacist for disposal or may be destroyed by the administrator or designee with one witness. Facilities holding a Special-ALF permit issued by the Board of Pharmacy may return dispensed medicinal drugs to the dispensing pharmacy pursuant to rule 64B16-28.870. This practice requires the facility to have a monthly audit by a pharmacist. Of course, the permit has an accompanying fee; however, having a monthly audit from a pharmacist helps keep your facility’s medication storage in compliance.
The surveyors will be looking to see that medications are stored properly and are returned to the family or appropriate person and that documentation reflects the return. With resident safety a priority, being vigilant about proper medication handling, storage and disposal is a must.