Guidelines for Medication Administration in Schools
Guideline #2: Roles
Accountability and responsibility for linking systems of student health needs and educational success is shared among LSNs/RNs, licensed prescribers, pharmacists, the school board and administrators, unlicensed assistive personnel (UAPs), school staff, parents, and students (see Figure 1 below). The contribution of persons in each of these roles is important to student success and the safe administration of medication within the framework of district policies. No employee may be coerced into compromising student safety by being required to administer medication if that person determines that it is inappropriate to do so.
Each person shares and depends upon the responsibility of others to contribute to maintaining a safe system of medication administration. Examples include a student who wears a medical alert bracelet and carries emergency medication per school district policies, a person administering medication who in a timely manner reported any irregularities to the LSN/RN, and a parent who keeps track of medication expiration dates and sends replacements to school without being reminded. This involvement sets a community norm with shared expectations and knowledge.
Education personnel and parents have varying levels of understanding of and ability to comply with school district health policies. Factors could include socioeconomic, physical, or psychosocial status, and cultural understanding and practices (e.g., the school might need a translator for verbal and written information related to medication administration). School administration will need to work with staff members and families to ensure understanding and compliance with policy.
The school administration should establish procedures and tools for communication among persons in various roles (e.g., parents’ and school staff members’ need for interpreters and translated materials).
Three channels of communication—among staff members, with students and their families, and with the community—clarify expectations, provide education, and facilitate discussion related to student medication administration issues.
Encompassed in communication of policy and procedures are a handbook, health advisory committee, newsletter, web site, posters, and job descriptions. Translators, translated materials, and advocates should be made available when needed.
With ongoing open communication between the parent/legal guardian and LSN/RN, changes in medication can be quickly communicated by the parent/legal guardian to the LSN/RN, and the parent/legal guardian can receive student medication updates from the LSN/RN in a timely manner. The LSN/RN can also, with parent permission, contact the student’s health care provider to ensure continuity of care and changing medications over time. This is especially critical for students with chronic health problems and/or special needs.
All communications need to be tailored to the diverse populations served in the school district and done in a manner consistent with data privacy regulations in D&A, Family Educational Rights and Privacy Act (FERPA), Health Insurance Portability and Accountability Act (HIPAA), Individuals with Disabilities Education Act (IDEA), the Minnesota Government Data Practices Act (Chapter 13), MMHA, and MMRA.
In response to requests from parents/legal guardians and students for medication administration in school, the LSN/RN will assess and create with the family and students a means for safe administration of medication, utilizing district policy and procedures. The LSN/RN may develop a more formal plan based upon individual student health needs (e.g., an individualized health plan and/or emergency care plan) and participate as appropriate in an individualized education plan (IEP) and/or 504 plan. See the glossary for further information on these plans.
In addition, it is important that community resources be utilized to support a system of safe medication administration. A health advisory committee can help achieve this goal; see further discussion in Minnesota Guideline 2.5.
School board members, school administrators, parents, students, LSNs/RNs, licensed practical nurses (LPNs), paraprofessionals, UAPs, and teachers are expected to comply with school district medication policy regarding prescription, over-the-counter (OTC), complementary and alternative medicines (CAMs), and/or emergency medicines.
According to Minnesota Statutes § 121A.22, subd. 4, the school board is to develop procedures for their school district. Ways in which the school board ensures the procedures are carried out include: periodically reviewing aggregate data on the health of district students (e.g., analysis of the number of students taking medications, changes over time, and medication administration procedures that need changing); allocating funding from the district budget for health-related resources (personnel, materials, space, etc.); being accountable for enforcement of the medication administration policy; reviewing medication policy annually and updating it as necessary; ensuring school staff training that includes administration of medication; planning for improved access to specialty support, which is especially important for school districts without full-time LSNs/RNs on staff; and setting up an agreement for school health consultation with an individual physician, an LSN/RN, local community clinic, hospital, or public health agency.
To ensure optimal student safety regarding medication administration, the school district needs to have an LSN/RN to administer the health services of the district. Whether the school district has its own school nurse staff, a nurse hired under contract, or no school nurse, the law (see Minnesota Statutes §§ 121A.21) states that schools need to develop and use district policy in conjunction with a knowledgeable LSN/RN or public/private health providers or health related organizations.
School administrators are accountable for implementing the medication administration policy; guiding the planning, gathering, and periodic board review of aggregate student health information, in conjunction with the LSN/RN; providing the needed staff, financial, and material resources for safe medication administration; drawing on the advice of other medication experts in the community when making decisions; assist the LSN/RN in arranging for staff development; and studying demonstration projects on medication administration for information to enrich local policies and procedures.
The Emergency Treatment for Minors Act (Minnesota Statutes § 144.344) allows schools to make emergency decisions about sensitive health issues and concerns and physicians to provide immediate care while parents are being contacted.
A health advisory committee can provide input to school policy and procedures. It should reflect a balance of the internal school community and external community at-large––such as LSNs/RNs, paraprofessionals, UAPs, teachers, parents, school board members, public health agency representatives, licensed prescribers, pharmacists, and non-public school members––who counsel the school board and school administration.
The role of parents/legal guardians, along with their children, is to follow and support the school district policy and procedures regarding medication administration; provide representation on the health advisory committee and advocate for safe administration of medication; and communicate with the school about their children’s medication needs in schools. Communication might focus on getting medications to school; participating in development and use of an IHP or other plan; signing the parent authorization form; obtaining a licensed prescriber’s order for medications; transferring medication self-carrying requests; and discussing student self-administration of medications, refusal, or non-compliance with medication administration.
The roles of students vary, depending on their age and developmental stage. Students at every age are learning about their health conditions and the role that medications have in managing or curing the problems. In the early years, the emphasis might be on students as recipients of medication, but even at young ages, students can take increasing responsibility for their medications. As students develop, it is important for them to learn to make decisions regarding their medication administration and skills in self-administration.
The students’ responsibilities are to be knowledgeable about their medications, take their medications correctly, and communicate any medication issues or concerns to parents/legal guardians, LSNs/RNs, LPNs, teachers, paraprofessionals, or UAPs, as appropriate. For example, younger students with diabetes using insulin will know about their medications but might need assistance administering sliding-scale insulin amounts, carbohydrate counting, and glucose monitoring; older students are likely to be able to do these activities themselves. One option is a written self-administration contract agreed to by the school, licensed prescriber, LSN/RN, parent/legal guardian, and individual student.
As employees who bring extensive knowledge of health services, medical systems, and best practices to the school setting, the LSNs or RNs take the lead in policy and procedure development for the district and assess the health needs of students, including those taking medications (prescription, OTC, CAMs, and/or emergency medications) as necessary. The practice of each nurse (salaried, contracted, or volunteer) is regulated by Minnesota Statutes §§ 148.171-148.285 and Minnesota Rules, chapter 6301 through 6340, commonly referred to as the Minnesota Nurse Practice Act. See the definition of the practice of professional nursing in the glossary.
To oversee and keep medications secure, the LSN/RN sets up the school’s medication system, recommends the purchase of supplies, sets up a double-lock storage system, decides where keys are kept, refrigerates medication as needed, and purchases medication resource documents, such as the drug formulary and training materials. The LSN/RN sets up, maintains, and secures private medication and health records, which include medication documentation, medication counts, authorizations, and prescription orders.
The LSN/RN has input into choosing current staff members for delegation of medication administration and hiring of new health services staff. The LSN/RN trains and supervises staff members to whom the LSN/RN is delegating medication administration, communicates the delegation plan to delegatees, assesses their competencies, and provides sufficient oversight and supervision.
The LSN/RN also assesses the medication needs of the aggregate student population. In this way, the LSN/RN can see patterns of population-based health problems that call for further investigation or reporting.
LPNs can administer medications to students under the delegation of a physician or LSNs/RNs. An LPN is able to monitor students’ responses to medication administration. LPNs would be expected to communicate significant information to physicians/prescribers, LSNs/RNs, and parents regarding students’ health. Responsibility for delegation to other nursing personnel and supervision of the nursing personnel are within the scope of practice of LSNs/RNs. If a physician or LSN/RN delegates medication administration to a UAP, it is within the scope of an LPN to monitor that individual’s performance of these activities.
Anyone designated, willing, and trained can serve as a UAP in schools (e.g., a health assistant, teacher, school administrator, or student services staff member); they are “unlicensed” in terms of providing health services. Under the delegation and supervision of an LSN/RN, UAPs can perform medication administration based on school district policy and procedures. In order to perform medication administration functions, the UAP needs to have appropriate training to perform these functions, written documentation, and annual evaluation of this individual’s competency; knowledge of policy and procedure; and be willing to communicate to the LSN/RN his or her own ability to perform medication administration, document medications administered, and report to the LSN/RN any inconsistencies or deviations from expected procedures. If uncomfortable with performing medication administration, a staff member has the right to ask for education and additional supervision about medication administration.