Determining Client Competency to Self Administer Medication
Recently, some organizations have been challenged on their TJC surveys by the issue of how they demonstrate that their clients are competent to self administer their own medications. The following is a finding from one such survey and is typical of surveyor findings in this area: "The clients in this program self administer medications. The record does not document that the client has been determined competent to self administer medications."
TJC standards allow for self administration of medications but require that the organization determine that the client is competent to do so. The relevant standard is MM.06.01.03 in the Medication Management chapter of the 2013 Behavioral Health Manual. Element of performance (EP) # 7 states: "When the individual's medications are prescribed or dispensed by the organization, the organization determines that the individual or the family member who administers the medication is competent at medication administration before allowing him or her to administer medications."
So, how does a program determine that a client is competent to self administer their own medications? The following is a checklist of key skills that the client should be able to demonstrate in order to be deemed competent to self administer their own medications:
- The client is able to state the name(s) of the medication.
- The client is able to state the purpose of the medication.
- The client is able to state when and how much medication should be taken and any other instructions about taking the medication (e.g. with food.)
- The client is able to state the common side effects of the medication and what to do if those side effects are experienced.
- The client is able to state whether or not he/she should drink alcohol while taking the medication.
- The client is able to state the potential consequences of not taking the medication or of not taking the medication properly.
- The client is able to state what to do if he/she misses a dose, takes a wrong dose, or experiences an adverse reaction to the medication.
The client's competency to self administer medications should be reassessed on an ongoing basis and addressed during the treatment planning review process.
In addition to determining the client's competency to self administer, TJC also requires a written policy on self-administration of medications. Standard MM.06.01.03 EP 1 states: "If self administration of medications is allowed, the organization has a written policy that addresses the training and supervision of the individual served to guide the safe and accurate self-administration of medications."
The policy on medication self administration should address the following key elements:
- The specific type(s) of self administration that the program will utilize:
- Supervised self administration: In this procedure, the client is self administering their own medication under the supervision of a staff member. The staff member may be prompting or coaching the client. Typically, the staff member records the act of self administration on some type of medication record.
- Independent self administration: In this procedure, the client is self administering their medication on their own without the supervision of a staff member. In this scenario, clients often are in charge of storing their own medications. Typically, there is no recording of the act of self administration.
- Where the medication will be stored:
Whether stored in a staff office or in a client's own room, the policy needs to dearly describe the procedure for where the medications will be stored; who has access to them; and how they will be kept secure. If the medications will be held by the program (e.g. in a staff office), this area needs to be inspected on a regular basis to ensure that meds are being stored appropriately. Standard MM.03.01.01 states: "The organization inspects all medication storage areas periodically, as defined by the organization, to verify that mediations are stored properly." Ideally, this inspection should be done by someone other than the staff who are routinely handling the medications; i.e. it should be a "fresh set of eyes.") This inspection should also be documented on a checklist and findings shared with the program manager and staff.
- How staff will be trained on the function of supervising clients' self administration of medication:
It is not uncommon in behavioral health settings that the staff who are supervising the self administration of medications are non-nursing staff. Thus, it is critical that they receive appropriate training on the medications commonly taken by their clients, their purposes and side effects, and how to effectively supervise the self administration of these medications. Their training and competency assessment on these skills should be documented in their Human Resource file.
- How clients will be educated about their medications and determined to be competent to self administer:
This section of the policy should describe the process for educating clients about their medications: purposes, side effects, instructions, etc. It should also describe the process for determining the client's competency to self administer (in keeping with the skills outlined in the first section of this article.).
As a resource, we are providing a Sample Medication Competency Tool.