RCPA - Rehabilitation and Community Providers Association


Medication Administration Training Draft Bulletin Released for Comment
October 15, 1999

The Office of Licensing and Regulatory Management, Department of Public Welfare has released a second draft of the Medication Administration Training bulletin for comment. The bulletin, which supports the 3800 Regulations governing Child Day Treatment and Residential Treatment Facilities, is proposed to be effective in June 2000. Members are asked to review the draft and submit comments to Kris Ericson at the Association by October 25.

Department: Licensing and Regulatory Mangement Bulletin
Subject: Medication Administration Training for Child Day and Residential Treatment Facilities.

DRAFT - October 6,1999


Child Residential Facilities and Child Day Treatment Facilities Potential Training Sources


55 Pa. Code Ch. 3800 regulations titled "Child Residential and Day Treatment Facilities", apply to a variety of facilities that serve children with diverse needs. The regulations include a requirement that in order for a non-medically licensed/certified/ registered staff person to administer medications to children, the person must complete a Department approved training course.

Consumers, child advocates, service providers, and licensing professionals within the Department have identified the importance of increasing safety protections associated with the administration of medications. The criteria and procedures contained in this bulletin were developed as a result of extensive research of existing medication programs in Pennsylvania, involvement and discussions with external stakeholders, and review of medication administration policies for state operated children and youth programs, licensed child residential facilities, and licensed community homes for individuals with mental retardation.


The purpose of this Bulletin is to transmit criteria and procedures that the Department of Public Welfare will apply when determining what will constitute a "Department-approved medication administration course" as specified in 55 Pa. Code, 3800.188 (relating to medications administration training).

Medications administration training sources must apply to and receive written approval from the Department prior to conducting medications administration training. The criteria established in this Bulletin provide the basis for the Department to review and approve medications training proposals.

The Department will maintain a listing of approved Medication Administration Training Sources. This list will be made available to all facilities under the scope of 55 Pa. Code Ch. 3800.

The Department will monitor compliance with this Bulletin through its licensing inspections of facilities.


Child residential and day treatment facilities are responsible for:

Selecting the training source that they will use.
Verifying that the selected training source is Department-approved.
Assuring that all appropriate staff persons receive the required training and maintaining records to verify the medication administration training status of trained staff persons.
Assuming costs associated with the training.
Conducting and documenting evaluations of non-medically Iicensed/certified/registered staff persons who administer medications.


Organizations or individuals interested in being a Department-approved training source should submit a proposal including the elements specified in this bulletin.
The criteria upon which approval will be based is developed to protect the health and safety of children, while allowing training providers reasonable flexibility to meet a variety of service provider needs and circumstances. Training received should prepare staff persons to have a level of competency that will assure children are adequately protected from the risks associated with the administration of medication.


55 Pa.Code 3800.188. Medications administration training.

(a) A staff person who has completed and passed a Department approved medications administration course within the past 2 years is permitted to administer oral, topical and eye and ear drop prescription medications and epinephrine injections for insect bites.

(b) A staff person who has completed and passed a Department approved medications administration course and who has completed and passed a diabetes patient education program within the past 12 months that meets the standards for Diabetes Patient Education Programs of the Pennsylvania Department of Health is permitted to administer insulin injections.

(c) A record of the training shall be kept including person trained, date, source, name of trainer, content and length of training.


Training proposals may include any audience focus such as statewide; one geographic area of the Commonwealth such as one region, county or city; a group of facilities; a single facility; or a specific program type (such as secure detention, mental retardation, day treatment, etc.).


Three primary options for training methodology are envisioned by the Department. The Department's intent is to allow for a variety of training methods.

Train the Trainer. This method trains trainers who in turn provide training to the staff persons who will be administering medications to the children.

Direct Training. This method provides direct training to the staff persons who will be administering the medications to the children.

Combination. This method combines the use of both the Train the Trainer and Direct Training methods.

Training must be delivered through direct, face-to-face interaction. Use of video, computer, or tele-conference training as the sole methodology is not permitted.


For both the Train the Trainer method and the Direct Training method, the trainer of trainers (in the Train the Trainer method) and the direct trainer (in the Direct Training method) must have one of the following levels of professional development:

A licensed physician.
A licensed physician's assistant.
A registered pharmacist.
A registered nurse.
A certified registered nurse practitioner.
A licensed practical nurse.

The trainer of trainers and the direct trainer must have experience in public speaking, teaching or staff development/training. Background experience in pediatric medicine and the provision of services to children is preferred.

In the Train the Trainer method, the individual who is trained by the trainer of trainers must meet the minimum qualifications for child care supervisor as specified at 55 Pa.Code 3800. 54(d) (relating to child care supervisor) and must be retrained by the training source at least every two years.


The following elements must be contained in a proposal.
1. Anticipated date training will be available.
2. Targeted geographic area or program type.
3. Training methodology (e.g. Train the Trainer, Direct Training, or
4. Supporting documentation that verifies that the trainer(s) has the required
level of professional development and experience, as specified in the preceding section on Authorized Instructors.
5. A detailed, descriptive outline of the training curriculum.
6. A time schedule that describes the total time required to complete the
training and each component of the training.
7. The maximum and minimum number of students that can be
accommodated in any class.
8. A description of the teaching strategies and methods to be used.
9. The criteria to be applied to determine successful completion of the
course including testing procedures to measure the trainee's ability in both knowledge and skill areas. Testing provisions must verify the competency of staff persons for each component area of the training including demonstration of competence.
10. The process to be followed in awarding a certificate to validate that course work has been successfully completed. A sample certificate to be issued by the training source should be included.
11. The process to be followed to assure that each staff person who has responsibility for administering medication to children is made aware that their certification status expires and that retraining is required once every two years as specified in 55 Pa. Code 3800.188 (a).
12. A packet of sample training materials to be used in teaching the course.
13. The method, resources, time schedule, and any sampling procedures to be employed to complete quality assurance monitoring of the effectiveness of the training. Monitoring must include on-site direct observation and monitoring of staff persons by medically licensed/certified/registered personnel of the training source, as well as a pre- and post-evaluation.
14. The fee for training individuals or for group training.
15. The record system to be maintained by the training source to accurately record persons enrolled, trained, issue and expiration dates of certificates, test results, quality assurance monitoring, and other components of this bulletin.


Training content must include the following:
1. Instruction on reporting and observation skills. The staff person should be
skilled in observing and reporting changes in physical appearance, emotional adjustment and behavioral activity. The trained person must be knowledgeable about the reporting of significant changes to the appropriate person within the appropriate time frames and procedures.

2. Types of medications and their effects. Staff persons should understand and
be able to recognize through observation skills, the desired, unwanted (both expected and unexpected), or no apparent desired effects of medications including potential medication interactions. They should understand the categories of medicine including prescription and non-prescription medicines. They should understand the difference between controlled and non-controlled medicines.

3. Staff person responsibilities in the medication process. The staff person
who has successfully completed training should know the limits of his ability to administer medications to children. They should be able to recognize and distinguish an individual's medication and know how to administer the proper dosage of medicine at the proper time. Staff persons should know the circumstances under which a medication should not be given. They should be skilled in the proper handling techniques during medication administration so that issues relating to infection control are addressed.

4. Handling emergency and health-threatening situations. Staff persons should
be knowledgeable with how to handle both emergency and non-emergency conditions. They need to know how to access immediate and direct response to an emergency situation such as an allergic reaction or respiratory arrest. They also need to know how to access regular medical support.

5. Facility specific policy and procedures. Staff should have a thorough
understanding of agency policies and procedures regarding medication administration.

6. Patterns of communication and interaction within the facility and facility
supports that are outside of the facility but have a direct responsibility to protect the health of children
. Staff persons will need to understand how to elicit and convey information between health care professionals. For example, how will information about a newly prescribed medication be communicated to other staff and other key adults who have responsibility relating to the child? How will coordination of information as available from various health care providers be communicated to all involved parties including those persons who will be responsible for assuring proper administration of medication when a child is away from the facility?

7. Administration of Medication. Staff persons need to be familiar with what they
can expect to receive by way of instruction from the prescribing entity and know how to request and receive necessary clarifying information if needed. Staff persons need to understand and accept the seven "rights" of medication administration: right person, right medication, right dose, right route, right time, right method and right position. Staff persons must know the agency policy specific to the medication administration process. They must demonstrate proper procedures for administering medications. They must be able to determine when a medication error has occurred and what action should be taken.

8. Self-administration. Staff persons must be trained in their responsibilities to
support and assist the child in self-administration of medications under the requirements of 3800.189 (relating to self-administration of medications). The staff person should demonstrate the ability and willingness to appropriately instruct the child in the name, purpose and administration of his/her medications and actively encourage child participation in medication activities.

9. Regulatory Requirements. Staff must understand and be able to carry out the
requirements of the regulations specified in 3800.181 through 3800.189 (relating to medications administration). The facility shall conduct regular monitoring of staff persons to assure compliance with the medication administration sections of the regulations.


1. Submit four copies of the proposal to:
Director, Division of Licensing Regulations and Policy
Office of Licensing and Regulatory Management
323 Health and Welfare Building
P.O. Box 2675
Harrisburg, Pennsylvania 17105-2675
2. The Department will provide a written response for each proposal application
received. The response will either be an approval, disapproval, partial approval or a request for additional information. Rationale will be provided for any response other than an approval.
3. Proposals approved by the Department will be approved for a specified length of
4. The Department has right to withdraw approval at any time based on evidence of
violation with the conditions of the approved proposal, this bulletin, 55 Pa. Code Ch. 3800 or applicable law.
5. Initial proposals may be submitted immediately upon issuance of this bulletin and
may be submitted at any time thereafter.
6. Re-submission of the training proposal for continued approval, must be received
by the Department at least four months prior to expiration of the current approval. If the original proposal is unchanged, a short summary of the proposal referencing the proposal already on file with the department, is sufficient for requesting continued approval.
7. Approved training sources, who want to amend the scope, methodology, course
instructor or training content of their approved proposal must submit an amended proposal identifying any changes that are proposed.
8. Training source applicants will be given an opportunity to submit additional
information or clarifying information if needed by the Department, if such additional information is needed by the Department to make a fair determination on the suitability of the application.
9. Training may not begin until the training source has received a written approval
from the Department.

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