Medication Management Audit Tips

 

 Medication management relates to section 1.3.12 of the Health and Disability Services Standards and referred to in section D5.4 of the ARRC.  There are key reference documents which provide reference at facility level which should be used in conjunction and addition to your organisation policies and procedures.  These reference documents are (first two are key for residential care):

 

Medication errors of any type, when reporting through the audit process to MoH HealthCert as part of your audit, will receive a higher ‘weighting’ than other partial or non-attainments.  Even a single signature missing off an administration signing sheet may come into this category and mean your audit outcome is diminished.  Below are common errors which continue to be made:

Aspect of medication management 

Common Errors 

Medication charts

Not dated

Not signed by the prescriber

Not signed by the General Practitioner or Nurse Practitioner at each review (3 monthly)

Not legible

Allergies not documented (or inconsistent with other resident documents)

Transcribing on medication charts or PRN signing sheets

PRN medication charting does not include ‘indication for use’

Medication order does not include time, dose, frequency, route, type etc

Signing sheets

Missed signatures on the signing sheets

Only one signature (instead of two) on controlled drug administration records and register

PRN medication not signed for accurately

Self-medicating residents

Competency to verify self-medication not signed by prescriber

Competency for self-medication not signed as having been reviewed by prescriber (3 monthly)

Staff verification of self-medicating occurred not recorded on a shift by shift basis (as relevant to the individual residents medication order)

Not retaining a current list of all medication ordered for self-medicating residents

Storage

Medication not securely stored (also see ARRC D15.3(c)

Controlled drugs not entered accurately into Controlled Drug Register (at time of supply or return to pharmacy)

Controlled drugs not stored in locked cabinet in locked room

Drug trolley left in common areas unlocked

Expired medication continue to be stored on site (should be returned to pharmacy)

Medication for resident who has been discharge or deceased remain on site

Medication fridge temperature not monitored / recorded

Labels on medication containers not clear / legible

Identification of resident

Photograph not representative of current presentation of resident (photograph should be colour)

Photograph of residents not validated regularly

Medication errors

Not reported

Not managed (through an adverse event management process to ensure identification of contributing factor and preventive measures).

Competency

All staff (including Registered Nurses and Enrolled Nurses) involved in medication administration must have first successfully completed a medication competency

Annual review of medication competencies

If you’re uncertain about the competency of a particular staff member, do not be tempted to sign them off and monitor.  The risk is too high for the residents and your organisation.  Medication errors can be classified as ‘sub-standard care’ and due to the possible consequences, are at least a moderate risk.

Remember when changing staff around, the key priority is do you have a medication competent staff member on each duty and if controlled drugs are being administered, you need a minimum of two medication competent staff rostered on each duty.  Registered Nurses cannot be leaving the ‘hospital’ area of the facility to administer medication in other areas as this leaves the hospital residents vulnerable so this also needs to be factored into your rostering.  Refer to the Aged Related Residential Care Contract (ARRC) for further information.

Ensure your internal audits review the above common errors to verify you are providing safe and appropriate services in all aspects of medication management.

Health and Safety at Work 2015 implications for Aged care and Retirement Villages

I’ve been working through the new Health and Safety at Work 2015 legislation and have concerns about how this applies to not only care facilities and new reporting requirements, but also to Villages.  This legislation could cause all sorts of issues for you and in my view needs further clarification as to how it is to be applied to ARRC residential care setting and Villages that come under the RVA.

The Retirement Villages Association define a ‘Licence to Occupy’ as –

Licence to occupy – This is the most common form of occupation right in New Zealand. A licence to occupy gives you the right to live in your residential unit and to use to village facilities according to the terms of the licence to occupy. The ownership of the land and building remain with the village operator.”

The new Health and Safety at Work Act 2015 which applies from the 4th of April 2016 requires a PCBU (Person Conducting a Business or Undertaking) to report notifiable injuries or illnesses and all notifiable incidents. Looking closer at the terminology used in the legislation is states in relation to responsibility to notify

Health and Safety at Work Act 2015.
Sub Section part 2 – clause 37 Duty of PCBU who manages or controls workplace  (
this appears to apply to Village operators as well as ARRC providers)

(4) In this section, a PCBU who manages or controls a workplace—

(a) means a PCBU to the extent that the business or undertaking involves the management or control (in whole or in part) of the workplace; but
(b) does not include—
(i) the occupier of a residence, unless the residence is occupied for the purposes of, or as part of, the conduct of a business or undertaking.

The red text seems to be the rationale for notifications being required from care facilities but it would seem it also applies to village units, studios and apartments.  How are you going to know if your village residents have had an injury or illness which is classified as notifiable?

Part 1 Section 23 –  Meaning of notifiable injury or illness

(1) In this Act, unless the context otherwise requires, a notifiable injury or illness, in relation to a person, means—
(a) any of the following injuries or illnesses that require the person to have immediate treatment (other than first aid):

(i) the amputation of any part of his or her body:
(ii) a serious head injury: (
This could apply in the case of a fall where a resident has a knock to their head?)
(iii) a serious eye injury:
(iv) a serious burn:
(v) the separation of his or her skin from an underlying tissue (such as
degloving or scalping): (
Does this apply to skin tears of a particular size?)
(vi) a spinal injury:
(vii) the loss of a bodily function:  (
Fall resulting in fracture?)
(viii) serious lacerations:

(b) an injury or illness that requires, or would usually require, the person to be admitted to a hospital for immediate treatment:
(c) an injury or illness that requires, or would usually require, the person to have medical treatment within 48 hours of exposure to a substance:

Implementing this into this sector may be difficult due to the rights to privacy of those living in ‘independent’ ORA situations. The key definer in this section is clause a) any of the following injuries or illnesses that require the person to have immediate treatment (other than first aid).  If an ambulance is called to attend to a village resident this could be deemed ‘immediate treatment’.

Part 1 Section 24 – Meaning of notifiable incident –

(1) In this Act, unless the context otherwise requires, a notifiable incident means an unplanned or uncontrolled incident in relation to a workplace that exposes a
worker or any other person
to a serious risk to that person’s health or safety arising from an immediate or imminent exposure to—

(a) an escape, a spillage, or a leakage of a substance; or
(b) an implosion, explosion, or fire; or
(c) an escape of gas or steam; or
(d) an escape of a pressurised substance; or
(e) an electric shock; or
(f) the fall or release from a height of any plant, substance, or thing; or
(g) the collapse, overturning, failure, or malfunction of, or damage to, any
plant that is required to be authorised for use in accordance with regulations;
or
(h) the collapse or partial collapse of a structure; or
(i) the collapse or failure of an excavation or any shoring supporting an excavation;
or
(j) the inrush of water, mud, or gas in workings in an underground excavation or tunnel; or
(k) the interruption of the main system of ventilation in an underground excavation or tunnel; or
(l) a collision between 2 vessels, a vessel capsize, or the inrush of water into a vessel; or
(m) any other incident declared by regulations to be a notifiable incident for the purposes of this section.

Clearly the majority of these apply to manufacturing and industrial sites however some could potentially be applied to the care and village setting.

What do you see as your liabilities?  What is the responsibility for the operator in managing potential risk?  Which assessment tools and accompanying definitions are we best to apply if any?  If alcohol consumption by a resident or failing cognitive state is likely to contribute to their safety, where are the boundaries for responsibility between the resident and the operator? 

Share your comments ….