Weekly Q&A
This was sent to NYSCAL from The Department of Health:
Following a med change, are we allowed to split scored pills until we can get them split from the pharmacy? I understand that we would have to waste the remaining half pill.
Response: Per Medication Assistance FAQ from August 25, 2005
Question: What is the procedure if medication (non-controlled or controlled substance) has to be split in half?
Response: It is strongly recommended that splitting occur at the pharmacy by a licensed health professional prior to delivery when it is known that the order calls for a 1/2 tablet. If the prescription order is written for a ½ tablet and the pharmacy has not provided the facility with a ½ tablet in the blister packs or other containers, the staff must split the scored tablet at the time of assistance not upon receipt.
If the prescriber orders the appropriate number of scored tablets in the correct dosage for splitting, staff must split the scored tablet at the time of assistance and save the remaining ½ tablet for the next scheduled medication assistance; only if the container is a bottle.
Half tablets may not be placed back into a blister pack. For example, if the pharmacy provides fifteen 10 mg scored tablets for a prescription that is written for a 30 day supply of 5 mg of medication, facility staff may split the tablet and assist the resident. Please contact your pharmacy for current proper handling of medication when a prescription has changed and splitting medication is needed to reduce waste.
However, if the prescription is not written for the appropriate number of scored tablets in the correct dosage for splitting, staff must split the scored tablet and the remaining ½ tablet may NOT be retained for later use. For example, if the prescription is written for sixty 10 mg scored tablets for a 60 day supply of 5 mg of medication, the unused ½ tablet must be wasted with a 2nd staff member as witness/co-signer. This partial dose should be wasted in a manner that causes the ½ tablet to be unrecoverable (e.g., not in a sharps container). The destruction must be documented on the Narcotic Administration Sheet, in the remarks column next to the assistance entry. Staff should be wearing gloves when splitting the tablet.
How should we store a prn medication that is in a container too large to fit in the med cart? This was cited during our recent survey. Tylenol was not in the cart but was in the proper, labeled spot in the med room. Why must prn medications be on the med cart at all when they are readily available in the med room?
Response: The regulation does not specifically address PRN’s in medication carts. PRN’s must be available for residents as ordered and as needed. Need more information on the citation described for further assistance.
Are we allowed to pre pour medications as long as they are clearly labeled, securely stored and not set up prior to 2 hours before the med pass?
Response: Per Medication Assistance FAQ from August 25, 2005 , Yes. Non-controlled medications may be pre-poured no more than 2 hours prior to assistance. In accordance with regulation 487.7(f)(6) and 490.7(d)(11)(v): In any system for supervision and assistance, removal of a dose from the container, or measurement or preparation of medications, must be performed by the person providing assistance with intake, except that insulin syringes may be pre-filled by a nurse.
Our survey here was conducted in the summer and to date we have not had any response. Should we be making contact with the department?
Response: Yes, please contact the Regional Area Office Director.
Western: Tracey Graney
Central: John VanDyke
Capital: Joe Santiago
MARO: Brian Parente
————————————————————————————————————-
Q: From an EALR: Long story short, I issued a resident a 30-day notice of which we are at the end of. I know DOH’s expectation is we pursue a special proceeding. This particular resident resides in memory care and requires a purees diet and 1:1 supervision for meals, both of which we are unable to provide. Her son is in disagreement with the SLP recommendations and therefore refuses to move her.
I’ve never had to go through a special proceeding. Are you familiar with the process? Do you have any other suggestions on how to handle this?
A: (Answer from attorney) This is a difficult situation. My suggestions are to either offer the son the chance to use his chosen outside provider’s assessment as a “second opinion” or start the special proceeding just to get leverage in the negotiation with the son. Once the lawsuit is filed and served most people begin to doubt their position and become more reasonable. If that happens you can slow the proceeding by adjourning court dates. I wish there was more of a middle ground but this happens a lot these days and I haven’t found any other approaches that work.
If members need legal assistance/support, please contact caudi@nyshfa-nyscal.org
NYSHFA | NYSCAL CONTACTS:
Christina Audi, MHA, LNHA
Executive Director, NYSCAL
caudi@nyshfa-nyscal.org
518-462-4800 x 13
