3.10.3 Notification: Medication Administration Protocol

A student’s right to receive medication at school exists in the following federal laws: 

• Public Law 93-112; 87 Stat. 394; 29 United States Code Section 794; (H.R. 8070). "Rehabilitation Act of 1973." 
• Public Law 101-336; 104 Stat. 327; 42 United States Code sections 12101-12213; (S. 933). "Americans with Disabilities Act of 1990." 
• Public Law 105-17; 111 Stat. 37; 20 United States Code sections 1400-1485; (H.R. 5). "Individuals with Disabilities Education Act Amendments of 1997." 

CA Education Code 49423 also provides statutory authority for providing assistance in administering medication in California schools. CA Education Code 49423 states: Notwithstanding the provisions of CA Education Code 49422, any student who is required to take, during the regular school day, medication prescribed for him by a physician, may be assisted by the school nurse or other designated school personnel if the school district receives (1) a written statement from such physician detailing the method, amount, and time schedules by which such medication is to be taken and (2) a written statement from the parent or guardian of the student indicating the desire that the school district assist the student in the matters set forth in the physician's statement. (Emphasis supplied.)

CA Education Code 49414 requires school districts to provide emergency epinephrine auto-injectors to school nurses or trained personnel who have volunteered to use such injectors to provide emergency medical aid.

1. Medication oversight/administration is the responsibility of the site administrator.

2. The site administrator should designate a voluntary staff member (and one or two alternates as back up) who will be responsible for administration of medication. 

3. Prior to the administration of medication the following procedures must be in place.

• a. Medication Form (one per medication)
  • i. Completed and signed by a medical provider.
  • ii. Completed and signed by parent/guardian/caregiver
  • iii. Completed annually or when there is a change in the medication order.
• b. Medication is supplied by parent/guardian/caregiver
  • i. In a pharmacy labeled container/dispenser
  • ii. Any medical equipment needed to dispense medication is supplied by the parent/guardian/caregiver.
• c. Medication is logged in the School Medication Log when it arrives onsite.
  • i.  All controlled substances are counted and recorded upon arrival at school in the presence of the parent/guardian, or designee delivering the medication. The staff members who perform and record the count and the parent or guardian should sign the Student Medication Log verifying the count. (CFR Title 21, Section 1300.01)

4.   Document medication administration by:

• a. Entering each medication administration in the Student Medication Log
• b. Subtracting each dose of a controlled substance that is administered from the total count remaining. Discrepancies between what has been documented as administered and the amount remaining are reported immediately upon discovery to the site administrator, school nurse or other duly qualified supervisor of health, and, if necessary, to the appropriate law enforcement agencies. (CFR Title 21, Section 1300.01)

5. Storage of Medication:

• 1. Medication should be stored in a manner that is secure and maintains the medication’s effectiveness. Medication should be stored in a secure and accessible cabinet or drawer unless they need to be refrigerated or when otherwise indicated.
• 2. Place the medication in a bag labeled with the student’s name, and include a copy of the Medication Form and Student Medication Log.
• 3. Write the location of the Medication on the Emergency Care Plan if there is one.

6. Medication Administration: Follow the steps in the “Medication Procedure” that applies to the specific medication (for example Oral Medication Procedure for an oral medication and Inhaled Medication Procedure for an inhaled medication). 

7. Self-Administration: If a medical provider and parent/guardian/caregiver have indicated on the Medication Form the student may self-administer the medication with assistance, follow the protocol for Self Administration of Medication, With Assistance. The designated staff member should assist with steps in the administration procedure that the student is unable to perform. Storage of medication while on site should still be secure and confidential and documentation should be completed.

8. Medication Retrieval or Disposal:

• a. Return any unused, expired, or discontinued medication to the student’s parent/guardian/caregiver when possible.
• b. Two weeks prior to end of school, send home “Request for Retrieval of Medication” to any parent/guardian/caregiver of a student with medication on-site
• c. Medication that is not returned to the parent/guardian/caregiver is disposed of by the end of the school year. 
  • i. Medication not retrieved must be put into an envelope and sealed. Another school staff member must witness medication being put into the envelope. 
  • ii. Site Administrator or designee should bring the medication in the sealed envelope to a Safe Medicine Disposal site (see list of Safe Medicine Disposal sites in the School Health Manual, Section C).
  • iii. Document on the School Medication Log:
    • 1. medication name
    • 2. date of disposal
    • 3. method of disposal
    • 4. source for directions of disposal method
    • 5. signatures of person disposing the medication and the witness to disposal
    • 6. signature of Safe Medicine Disposal site representative receiving the sealed envelope 
• d. For the health and safety of all students, medication must not be sent home with students. 

9. Errors that occur in the administration or storage of medication are reported immediately to the school site administrator and to the direct supervisor of the person who discovers the error. The student’s parent/guardian/caregiver and the student’s authorized health care provider, if necessary, are to be notified.

• a. Errors are recorded on the back of the Student Medication Log. 
• b. An incident report is also completed when: 
  • i. emergency services or medical attention was required
  • ii. there is an error in the count of controlled substances (see Section 4b)
  • iii. site administrator and/or supervisor of health deem it necessary

10. Stock Epinephrine

• a. CA Education Code 49414, as amended by Senate Bill 1266, effective January 1, 2015, authorizes school districts to provide emergency epinephrine auto-injectors to school nurses or trained personnel who have volunteered, and provides that school nurses or trained personnel who have volunteered may use epinephrine auto-injectors to provide emergency medical aid to persons suffering or reasonably believed to be suffering from an anaphylactic reaction.
• b. Anaphylaxis is a potentially life-threatening hypersensitivity to a substance. The reaction can occur within seconds or minutes of encountering an allergic trigger, including but not limited to an insect sting, food allergy, drug reaction (e.g., antibiotics, aspirin and non-steroidal inflammatory drugs), and exercise. Other causes include latex and, less commonly, food-dependent, exercise-induced anaphylaxis and idiopathic anaphylaxis (unknown cause). 
• c. Symptoms of anaphylaxis may include shortness of breath, wheezing, difficulty breathing, difficulty talking or swallowing, hives, itching, swelling (of the face, lips, tongue, or other parts of the body), shock, or asthma. Other symptoms may include narrowing of the airways, rashes, hoarseness, nausea or vomiting, weak pulse, and dizziness. Individuals may experience anaphylaxis and not show any skin symptoms. Many individuals may have previously had only a mild reaction to an allergen, but subsequent exposure can trigger anaphylaxis. 
• d. Without immediate administration of epinephrine followed by activation of emergency medical services, death can occur.
• e. Provisions of the Stock Epinephrine Program:
  • i. Designated, trained school staff in each school is responsible for maintaining the stock epinephrine at the school, responding to cases of suspected anaphylaxis by determining symptoms, responding appropriately per training protocol, engaging emergency follow up steps, and documenting.
  • ii. With every case in which epinephrine is administered, the school staff who administered the medication should document on the First Aid Log, the Student Medication Log, an Injury/Incident Report, and the Report of Epinephrine Administration. The Report of Epinephrine Administration should be faxed to the Student and Family Services Division ASAP.
  • iii. Stock epinephrine is ordered and distributed to school sites by the Student and Family Services Division. Replacement of used stock epinephrine is also coordinated through the Student and Family Services Division.

11. Stock Narcan: Each public and private elementary and secondary school in the state may voluntarily determine whether or not to make emergency naloxone hydrochloride or another opioid antagonist and trained personnel available at its school to provide emergency medical aid to persons suffering or reasonably believed to be suffering from opioid overdose.  If a school has opted to make emergency naloxone hydrochloride or another opioid antagonist and trained personnel available at its school, the procedures in SFUSD Administrative Regulation 5141.21 shall apply.  

• Fentanyl is a high potency synthetic opioid that is colorless and odorless and can cause rapid respiratory depression resulting in accidental death. It is both a prescribed drug, as well as a drug that is used illegally. All medication that is not from a doctor or pharmacy should be considered unsafe and suspicious for having fentanyl.
• Illegally manufactured fentanyl is sold illegally as a powder, dropped onto blotter paper, put in eye droppers and nasal sprays, or made into counterfeit pills that look like other prescription opioids. Importantly, fentanyl is also being mixed with other drugs, such as heroin, cocaine, methamphetamine, and MDMA.
• SFUSD has made emergency naloxone hydrochloride (Narcan) available to school sites with trained personnel.

12. A credentialed school nurse will hold an annual professional development on medication administration for school staff who are responsible for administering or assisting with medication to students.