CBRF/AFH February 2001 ETN
Medication Management Question and Answer
Date: September 4, 2001 - DSL-BQA-01-037
To: Community Based Residential Facilities CBRF
17 - OBSOLETED by
Adult Family Homes
From: La Vern Woodford, Chief, Resident Care Review Section
cc: Susan Schroeder, Director, Bureau of Quality Assurance
On February 8, 2001 an ETN was presented on medication management
issues in Community Based Residential Facilities (CBRF) and Adult Family
Homes (AFH). During the question and answer portion of the presentation
some information was not readily available. The following is a summary of
those questions and responses.
1. What are the Adult Family Home training requirements as it relates
to medications and medication administration?
Currently HFS Chapter 88.04 (5) (a-d) defines the training requirements
(5) TRAINING. (a) The licensee and each service provider shall
complete 15 hours of training approved by the licensing agency related to
health, safety and welfare of residents, resident rights and treatment
appropriate to residents served prior to or within six months after
starting to provide care. This training shall include training in fire
safety and first aid.
(b) Except as provided in pars. (c) and (d), the licensee and each
service provider shall complete 8 hours of training approved by the
licensing agency related to the health, safety, welfare, rights and
treatment of residents every year beginning with the calendar year after
the year in which the initial training is received.
(c) The licensing agency may require the licensee and service providers
to obtain training in amounts that exceed the minimum required under par.
(b) to ensure that resident health, safety and welfare are protected and
(d) The licensing agency may approve alternatives to the training
requirements in pars. (a) and (b) at a licensee’s request and if the
licensing agency determines that any of the following has occurred: (1)
The person has successfully completed substantially similar or related
training. (2) The person has successfully completed course work or an
academic degree program related to the care, maintenance and treatment of
the type of individuals served by the adult family home as identified in
the home’s program statement or other persons in need of care,
maintenance or treatment. (3) The person has acquired substantial and
up-to-date knowledge concerning care, maintenance, treatment and health,
safety, welfare and rights appropriate to a resident being served through
prior experience in licensed or certified programs which are substantially
similar to adult family homes.
In addition HFS 88.07 (2)(c) states: Services that are provided shall
be services determined by the resident, licensee, service coordinator, if
any, placing agency, if any, and guardian, if any, to be needed by the
resident and within the capability of the licensee.
As you read the administrative code the regulations do not specifically
indicate that adult family home staff must receive medication training.
However, staff must receive training related to health, safety and welfare
of residents. In addition, if a licensee is providing a service, they must
be competent to do so. Therefore, if adult family home staff are
administering medications they should first receive training related to
medication administration specific to the services they will be providing.
The type of services provided and the capability of the staff who will be
providing the service will determine the amount of that specific training.
2. What are the medication packaging requirements for adult family
HFS 88.07 (3)(a) Every prescription medication shall be securely
stored, shall remain in its original container as received from the
pharmacy and be stored as specified by the pharmacist.
Compared to CBRF medication packaging, there is not a defined
requirement in the adult family home regulation that specifies unit dose
packaging, label requirements, etc. The regulations simply state the
medication shall be maintained in the package that comes from the
3. What about packaging of prescription liquids like cough syrup and
injection medications like insulin in a CBRF?
Please refer to the BQA memo 01-001
related to over the counter packaging requirements. In regards to
prescription medications, unit dose or unit of use packaging is required
when unlicensed persons are administering medications without registered
nurse or pharmacist supervision. These unlicensed persons must take an
eight hour medication course prior to performing this task.
The unit dose or unit of use packaging is not required in a CBRF that
does use a registered nurse or pharmacist to supervise CBRF staff. The
pharmacist can provide alternative modes of packaging including bulk
bottles of liquid medications or insulin pen injections. The registered
nurse or pharmacist must provide training in administering medications
from the packaging that is utilized. The supervising registered nurse must
delegate administration of injections, which can include drawing up
insulin or utilizing insulin pens or other predrawn insulin. The five
rights of medication administration – right drug, right dose, right
patient, right time, and right route – must be adhered to at all times.
4. Can you explain secure storage of medications and what about a
This question is in reference to HFS
83.33 (3)(b)1 (exit DHS). The regulation addresses the fact that when medication
is in control of the resident the facility must provide a secure place to
store the medications in the resident’s room. A secure place does not
need to be a locked cabinet, drawer or refrigerator. If medications are in
the control of the facility, then medications must be locked.
5. If a medication is discontinued and we have the medications in a
mediset, can staff in consultation with the pharmacist pull out the
medication that was stopped?
The current regulations for CBRFs do not specifically address this
situation. However, if a medication is stopped, that medication must be
identified and destroyed per HFS
83.33(3)(j) (exit DHS). In some medication systems in CBRFs the medications are
separated and individually labeled, making it easier for staff to identify
the stopped medication. However, in other medication systems that place
all medications into time slot containers, it may not be easy to identify
medication that should be removed. In all cases where the medication is
not individually labeled, a pharmacist should be contacted to assist with
identification and review. In most cases the pharmacist will need to come
to the CBRF or have the medications brought to the pharmacy to remove or
change the medications. Professional judgement of the pharmacist should
prevail. In all cases, the CBRF must document all medication that was
removed or destroyed.
6. Can unlicensed CBRF staff accept a phone order?
During the ETN, a discussion occurred regarding the physician’s
authority to delegate tasks to many individuals. That information was
correct; however, under HFS
83.33 (2)(h) and 83.33 (3)(a) (exit DHS), the regulation specifically indicates
there must be a written physician’s order for medications, nursing care,
rehabilitation services and therapeutic diets. Phone orders that are from
physicians to unlicensed CBRF staff are not permissible. All emergencies
should be handled with common sense. Staff should call for emergency care
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