Administration of Medications

School districts, where medication is stored or administered, must register annually with MA DPH. In accordance with the School Health Controlled Substance Registration and School Epinephrine Controlled Substance Registration, a medication program manager shall be named and designated as the supervisor of the medication administration program, ensuring compliance with all policies and regulations.

The School Committee shall adopt a policy governing the administration of medications within the school system, following development of a procedure by the medication program manager and in consultation with the school physician. This procedure shall detail all necessary regulation requirements listed in 105 CMR 210.000 THE ADMINISTRATION OF MEDICATIONS IN PUBLIC AND NON-PUBLIC SCHOOLS. Review and revision of such policies and procedures shall occur as needed but at least every two years.

Medication is defined as both prescription and "over-the-counter" medications. Regulations require the following documentation be on file in the student’s health record prior to administration of any medication:

• A signed consent by the parent or legal guardian to give the medication
• A signed medication order from a licensed prescriber which is renewed at the beginning of each academic year and as needed

School nurses may administer specified over-the-counter medications to students with parental authorization, provided that they are administered within the parameters established by FRPS District “Standing-Orders” protocol. These protocols are signed annually by the FRPS school district’s physician, and are developed in conjunction with the Director of Nursing.

Medications should be brought to the school by a parent/guardian or designated responsible adult in a pharmacy or manufacture-labeled bottle as dispensed by the pharmacy. In accordance with standard nursing practice, the school nurse may refuse to administer a medication if there are concerns about safety, including potential adverse effects, and will inform the caregiver and licensed prescriber immediately.

All medications must be stored securely in the nurse's office, except when self-administration/self carry provisions are applicable. Students may self-administer medications following the criteria outlined in 105 CMR 210.006, and subject to:

• A school nurse evaluation of the student’s health status and abilities and deems self-administration safe and appropriate;
• Written consent from a parent or guardian;
• Written authorization from the student’s licensed prescriber, if requested by the school nurse.

Furthermore, Massachusetts General Law (MGL) c. 71, § 54B allows students with certain conditions, including asthma, life-threatening allergies, cystic fibrosis, and diabetes, to possess and self administer necessary prescription medications at school. This law overrides other school regulations and requires schools to permit students to carry and use prescription inhalers, epinephrine, enzyme supplements, and diabetes management tools such as a glucose monitoring test and an insulin delivery system, provided that the student's parent or guardian has given authorization and the student has been instructed in their proper use and is capable of self-administration, following Department of Public Health regulations.

The School Committee approves the school nurse to delegate responsibility to unlicensed school personnel for medication administration during regular school activities. Regular school activities are defined as all instructional/academic activities, as well as all activities organized or sanctioned by the school, including but not limited to, school-provided transportation, interscholastic sporting events, after school or extracurricular clubs or organizations, proms or other social events organized as part of the instructional/academic portion of the school, including overnight field trips.

Unlicensed personnel must receive training related to medication administration, as outlined in the regulation. Unlicensed school staff must meet the criteria detailed in 105 CMR 210.004 (2) and must be listed on the student’s medication administration plan. The school nurse, in consultation with the school physician, shall have final decision-making authority with respect to delegation and training on administration of medications to unlicensed school personnel consistent with the requirements established in this regulation and in Board of Registration in Nursing regulations, 244 CMR 3.00.

A school nurse shall be on duty and available virtually should consultation be required, including consultation for each dose of a “p.r.n” medication (with the exception of emergency rescue medications). Neither prescription medication nor over-the-counter medications can be administered by delegation by unlicensed school personnel without student specific medication orders from a licensed prescriber.

For the purpose of administering emergency medication to an individual student, including parenteral administration of epinephrine, the school nurse may identify individual unlicensed school personnel who may be trained in the administration of emergency medication to a specific student. With school committee approval, administration of Epinephrine may be administered during regular school activities (as defined above). Training and planning shall be in accordance with CMR 210.010: Administration of Epinephrine.

LEGAL REF: MGL. 71:54B
MGL c. 112, § 80B; 244 CMR 3.00

Dept of Public Health Regulations: 105 CMR 210.00