Assisted Living Medication Management: Packaging and Labeling

Medication errors have often been linked to improper labeling and packaging. These errors can be controlled by ensuring that medications received from the pharmacy are accurately labeled and that proper packaging is maintained. Medication administration is based on specific information provided on the medication label. Unfortunately, medications have been mislabeled by the pharmacy, resulting in medication errors. Therefore, it is incumbent upon the provider to verify that all medications received are accurately labeled and correspond exactly to the physician’s order.

Relevant Regulations

Adult Day Care (ADC):
Certification Standard I.F.(3)(c)

Family ADC:
Certification Standard I.D.(3)(c)

Adult Family Home (AFH):
Wis. Admin. Code § DHS 88.07(3)(a)

Community-Based Residential Facility (CBRF):
Wis. Admin. Code § DHS 83.37(1)(b)
Wis. Admin. Code § DHS 83.37(1)(c)
Wis. Admin. Code § DHS 83.37(2)(c)
Wis. Admin. Code § DHS 83.37(3)(a)
Wis. Admin. Code § DHS 83.37(3)(a)1
Wis. Admin. Code § DHS 83.37(3)(a)2
Wis. Admin. Code § DHS 83.37(3)(b)
Wis. Admin. Code § DHS 83.37(3)(d)

Residential Care Apartment Complex (RCAC):
Wis. Admin. Code § DHS 89.13(22)



1. When oral liquids are packaged in a unit dose oral syringe, does each syringe need to be labeled?

In a CBRF when medications are repackaged there must be delegation by an RN and then the repackaged medications must be labeled with the resident name, medication name and dose, and the instructions for use must be included.

Outside of the CBRF regulations, the standard of practice for a pharmacy to unit dose medications would be to have each syringe labeled. For other assisted living facilities although there may not be an specific regulation requiring a label safety standards indicate each syringe should be labeled if it is not immediately administered.

2. Can a nurse tell unlicensed staff to repackage medications?

In a CBRF and in a RCAC medication repackaging can be delegated by an RN to staff. In an AFH all medications must remain in the packaging received from the pharmacy.

Last Revised: January 9, 2020