Inspection Process: Family Assistance with Medications and Treatment

The list of top citations over the past quarter shows family assistance with medications or treatments peaking at #2, the highest this WAC section has been since its inception in 2004. This article is designed to assist in determining where the facility’s system may need strengthening, to avoid citation.

Family assistance with medications and treatments is an optional service; the assisted living facility or company must notify prospective and current residents and their legal representatives regarding whether the assisted living permits family assistance or administration of medications and/or treatments and, if so, the extent of any conditions or limitations of that service. Mention of this service, and any limitations or conditions associated with it, must be included on the facility’s disclosure form.

If the facility currently offers this service and is interested in transitioning to staff-only provision of medications and treatments, written notice must be provided and time allowed to move away from family management of meds and/or treatments, per WAC 388-78A-2710. An updated version of the facility’s disclosure form must be shared with all current residents and legal surrogate decision makers, if applicable, with signature indicating receipt of the document.

WHAT IS INCLUDED IN FAMILY ASSISTANCE?

Perhaps one of the first issues that creates confusion and subsequent citations is the fact that family assistance or administration of medications or treatments involves much more than simply families performing a specific task for the resident. WAC 388-78A-2290, section (1) highlights all that is included in this provision:

An assisted living facility may permit a resident’s family member to administer medications or treatments or to provide medication or treatment assistance, including obtaining medications or treatment supplies, to the resident.

In essence, family assistance, then, includes times when any or all the following services are conducted by family:

Ordering medications or treatments for a resident
Picking up medications or treatment supplies from the pharmacy or other location
Delivering medications or treatment supplies to the resident
Setting up medication organizers for a resident to self-administer
Helping a resident to self-administer medications or perform treatments
Administering medications
Administering treatments

If your facility allows family assistance with medications or treatments, you will need to ensure there is a distinct family plan in place that highlights every aspect of the WAC.

When pieces of the plan are missing, citations can result. It is highly recommended, then, that someone at the facility assists the family in completing the family plan, to ensure all parts of the plan are filled in.

The plan, in its entirety, should offer clear details on who will be doing the medication or treatment management, what specifically this person will be doing, and when the service(s) will occur. This plan provides information to facility staff, so they can step in and follow up if the family does not implement all or part of the plan.

In reviewing WAC 388-78A-2290, a family plan must include:

By name, the family member who will provide the medication or treatment assistance or administration.
Be sure the individual’s name is included here, not “daughter” or “son” or similar. This provides clear information for staff in the event this person does not perform his/her duties as outlined in the plan.
PRIMARY PLAN: A description of the medication or treatment assistance or administration the family member will provide.
Be sure details are included. For example, if family is picking up medications from the pharmacy and delivering them – which pharmacy does the resident use? How often does the family order and pick up medications? Are there specific days of the week/month when this occurs? The more detail included in the plan, the better. Imagine a caregiver or med aide (or another family member) needing to step in and fulfill this role – will the information in this plan offer them enough information to fill in?
ALTERNATE PLAN: If the family member named in the plan is unable to fulfill his or her duties as specified in the primary plan.
This alternate plan may include a replacement family member, or the facility can have a policy outlining standard alternate plan for any time a primary plan cannot be implemented. For example, a standard alternate plan may be that the facility staff will regain all aspects of resident medication management.
An emergency contact person and telephone number in the event facility staff observes a change in the resident’s overall functioning or condition that may relate to medication or treatment plans.
The entire family plan must be signed and dated by the following individuals:
The resident (if able)
The resident’s representative (if any)
The resident’s family member responsible for implementing the plan
A representative of the assisted living community

While the WAC does not outline how often this plan needs to be updated, it should be considered anytime a resident experiences a significant change in condition that warrants an ongoing assessment, and at least annually during routine assessments and negotiated service agreement reviews and updates. This will ensure a systematic review of the plan and allow for adjustments as necessary. The regulation does mention that the facility can require, through policy and procedure, the resident’s family member to notify the facility immediately should changes in medications or treatment plans occur.

Whenever a family manages any aspect of a resident’s medications, those medications must remain on the assisted living premises whenever the resident is on the premises. This means, in the event something could occur that impeded the family from providing the medication service, staff could step in and manage the medications without a break in service.

Because of the wide range of expectations with this regulation, it is simple to miss a part or two. Some issues that rise to the level of citation include:

No family plan in place when one is warranted
The plan does not outline the name of the family member responsible for implementing the plan
The primary plan is vague and lacks detail that would allow staff to step in and fulfill the role if necessary
The alternate plan is missing
All signatures are not included
The resident’s significant medications are not stored onsite
The plan is not up-to-date and reflective of the services family is providing

It is essential to include the family plan as part of the full assessment and negotiated service agreement planning, to ensure it is up-to-date and reflects the services the family is providing. Furthermore, the facility should have systems in place to learn when a resident’s medications or treatments change to ensure proper monitoring for the resident’s overall functioning and condition, and to watch for any adverse medication side effects and take proper action. Enhanced communication methods amongst staff, residents, and their families will aid in making family assistance or administration of medications or treatments a successful endeavor.

If you have questions related to assisted living regulations, processes, training, or nursing, contact Vicki McNealley via email, or call her at (800) 562-6170 extension 107.

Posted in Assisted Living, Survey & Regulatory