Guidelines for Medication
Administration in Schools
2022
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REVISION LOG
Changes to this document made in 2022 are noted in the table below.
Section Page Description of Revision
Revision
Date
4
12
HB 1085 related changes to RCW 28A.210.260
2/2022
7
20
Expired medications
2/2022
7
23
Disposal of medications
2/2022
9
31
Clarifying information added for stock epinephrine
8/2021
12
34
Addition of glucagon nasal spray
8/2021
13
35
Added summary of HB 1085/RCW 28A.210.355 requirements
8/2021
14
40
HB 1095 (RCW 28A.210.325) medical marijuana
8/2021
14
42
New subsection Stock Naloxone RCW69.41.095, 28A.210.390,
28A.210.395
8/2021
17
48
Added FAQ on expired medications
8/2021
17
49
Amended FAQs on administration of medical marijuana
8/2021
17
50
Amended FAQ on sunscreen
8/2021
17
51
Amended FAQ on administration of stock naloxone
8/2021
17
51
Added FAQ on delegation
8/2021
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Table of Contents
INTRODUCTION .................................................................................................................................................................... 7
Acknowledgements ......................................................................................................................................................... 7
Disclaimers .......................................................................................................................................................................... 7
Clarifications ....................................................................................................................................................................... 8
WASHINGTON STATE MEDICATION STATUTES ....................................................................................................... 9
Public and Private Schools – Administration of Medication – Conditions ................................................. 9
General Provisions ...................................................................................................................................................... 9
Public and Private Schools – Administration of Medication – Immunity from Liability –
Discontinuance, Procedure ........................................................................................................................................ 11
General Provisions ................................................................................................................................................... 11
WASHINGTON STATE NURSING PRACTICE: ARNP, RN, AND LPN ................................................................. 12
REGISTERED NURSE DELEGATION IN THE SCHOOL SETTING .......................................................................... 13
Provisions of the Nursing Care Delegation Statute and Regulations ....................................................... 13
Delegation Recommendations from Nursing Care Quality Assurance Commission (NCQAC) ....... 13
Principles of Delegation ............................................................................................................................................. 14
Delegation Process ....................................................................................................................................................... 14
Documenting Delegation ........................................................................................................................................... 15
Rescinding Delegation ................................................................................................................................................ 16
Transferring Delegation .............................................................................................................................................. 16
RN Delegation Considerations ................................................................................................................................. 16
School District Considerations ................................................................................................................................. 17
TRAINING OF UNLICENSED ASSISTIVE PERSONNEL IN THE ADMINISTRATION OF MEDICATION ... 18
ROUTES OF MEDICATION ADMINISTRATION ........................................................................................................ 19
Oral Medication (by mouth, gastrostomy tube, inhaled) .............................................................................. 19
Nasal Spray ...................................................................................................................................................................... 19
Topical Medication ....................................................................................................................................................... 19
Eye Drops ......................................................................................................................................................................... 19
Ear Drops .......................................................................................................................................................................... 19
Injection ............................................................................................................................................................................ 20
NURSING PRACTICE AND BOARD OF PHARMACY RECOMMENDATIONS ................................................. 20
Licensed Healthcare Providers (LHP) Who May Prescribe and Administer Medications ................... 20
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Out of State Prescriptions .......................................................................................................................................... 20
Receipt of Medication ................................................................................................................................................. 20
Inventory of Medication ............................................................................................................................................. 21
Storage and Security of Medication ...................................................................................................................... 21
Medication Administration Responsibilities ....................................................................................................... 22
Student not Reporting for Medication ................................................................................................................. 22
Student Refusal of Medication ................................................................................................................................ 22
Early Dismissal and Medication Administration ................................................................................................ 22
Changes in the Student’s Medication Order ...................................................................................................... 22
Expired Medications ..................................................................................................................................................... 23
Documentation .............................................................................................................................................................. 23
Other documentation considerations: .................................................................................................................. 24
Record Retention Requirements ............................................................................................................................. 24
Confidentiality and Privacy ........................................................................................................................................ 24
Discontinuing Medication.......................................................................................................................................... 25
Disposal of Medication ............................................................................................................................................... 26
Medication Error ............................................................................................................................................................ 27
STUDENT SELF-ADMINISTRATION OF MEDICATION .......................................................................................... 28
Asthma, Anaphylaxis and Diabetes Medication ................................................................................................ 28
Other Medication .......................................................................................................................................................... 29
ASTHMA MEDICATION .................................................................................................................................................... 29
Summary of Provisions ............................................................................................................................................... 29
RCW 28A.210.370 Students with Asthma states: ............................................................................................... 29
Special Considerations ................................................................................................................................................ 30
Summary of NCQAC Advisory Opinion - Asthma Management in School Settings ........................... 30
See Nursing Care Quality Assurance Commission-Request for Advisory Opinion from the
American Lung Association, Asthma Management in School Settings Committee (2000) .............. 31
ANAPHYLAXIS MEDICATION ......................................................................................................................................... 31
Summary of Provisions ............................................................................................................................................... 31
Special Considerations ................................................................................................................................................ 32
Standing Orders for Stock Epinephrine ................................................................................................................ 33
PARENT DESIGNATED ADULT (PDA) FOR DIABETES AND SEIZURES ............................................................ 33
DIABETES MEDICATION................................................................................................................................................... 34
Summary of Provisions ............................................................................................................................................... 34
Parent Designated Adult (PDA) ............................................................................................................................... 35
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Special Considerations from Guidelines for the Care of Students with Diabetes, 2018 .................... 35
SEIZURE MEDICATIONS ................................................................................................................................................... 36
Summary of Provisions ............................................................................................................................................... 36
Parent Designated Adult (PDA) ............................................................................................................................... 37
Special Considerations ................................................................................................................................................ 37
ADDITIONAL GUIDELINES .............................................................................................................................................. 38
Medication versus Non-Medication ...................................................................................................................... 38
Oxygen .............................................................................................................................................................................. 39
Medical Marijuana (Cannabis) .................................................................................................................................. 40
Opioid-Related Overdose Reversal Medication ................................................................................................ 41
Medication Orders for Students of Military Families ....................................................................................... 42
Medication Orders for Students Experiencing Homelessness ..................................................................... 42
FIELD TRIPS, SCHOOL SPONSORED EVENTS AND SUMMER SCHOOL ......................................................... 43
Field Trips Out of State and Out of Country ....................................................................................................... 44
DISASTER PLANNING ....................................................................................................................................................... 45
FREQUENTLY ASKED QUESTIONS ............................................................................................................................... 46
REFERENCES ......................................................................................................................................................................... 50
RCW/WAC ........................................................................................................................................................................ 50
Websites ........................................................................................................................................................................... 51
APPENDICES ......................................................................................................................................................................... 53
Links to Sample Forms ................................................................................................................................................ 53
Legal Notice ......................................................................................................................................................................... 55
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INTRODUCTION
The purpose of these guidelines is to review the provisions of Washington state medication
statutes detailed in Revised Code of Washington (RCW):
• RCW 28A.210.260
: Public and private schools—Administration of medication,
• RCW 28A.210.270: Immunity from liability—Discontinuance, and
• RCW 28A.210.275: Administration of medications by employees not licensed.
These guidelines provide recommendations for the safe administration of medication in
Washington state public and private schools. It is designed to be used by registered nurses (RNs),
licensed practical nurses (LPNs), school administrators, and unlicensed assistive personnel (UAP) to
administer medications to students in compliance with state and federal statutes. The document
provides general recommendations for medication management in schools, as well as links to
helpful resources and sample forms and tools.
Acknowledgements
The Office of Superintendent of Public Instruction (OSPI) acknowledges and thanks the following
professional nurses for their time and expertise in the development and review of the previous
editions of these guidelines:
• Shirley Carstens, MS, RN, FNASN
• Janice Doyle, MSN, RN, NCSN, FNASN
• Gail Park Fast, MN, RN, NCSN
• Lorali Gray, MEd, RN, NCSN
• Kathleen H. Johnson, DNP, MN, RN-BC, NCSN
• Alma McNamee, MSHA, RN
• Julie Schultz BSN, RN
• Robin Fleming, PhD, RN, NCSN
Gratitude is also extended to the Department of Health (DOH) Nursing Care Quality Assurance
Commission (NCQAC) for providing project funding and support for the original document, to the
Board of Pharmacy for review of the pharmacy section of the original document, and to Kristin
Hennessy of OSPI’s Office of Equity and Civil Rights.
Disclaimers
• Recommendations made in these guidelines should never be substituted for legal counsel
in any particular situation.
• Sometimes the law is silent or may be unclear; in these instances, it is recommended that
district administrators consult with district legal counsel and/or a risk management
consultant.
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• When addressing situations or questions, consider district policies and procedures that
should reflect current state and federal statutes as well as district practice.
• The provision of forms and documents in the appendices are samples only and are not
endorsed by OSPI or any Educational Service District (ESD).
• New statutes or treatment options may emerge after the publication of these guidelines
that supersede the information contained therein. School Nurses are professionally
responsible for knowledge and adherence to current law and standards of practice.
Clarifications
• The terms physician, licensed healthcare professional, licensed healthcare provider, and
health care practitioner will be referred to as LHP to describe Washington state healthcare
providers or professionals with prescriptive authority.
• The term unlicensed assistive personnel (UAP) will be used to describe unlicensed school
staff.
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WASHINGTON STATE MEDICATION
STATUTES
(RCW 28A.210.260 and 270)
These medication statutes authorize public school districts and private schools to implement
policies and procedures whereby school staff may administer medications to students at school
and school-sponsored events. Certain specific conditions must be in place. The laws provide that
when the conditions specified in statute and written instructions from a licensed health
professional (LHP) prescribing within the scope of their prescriptive authority are substantially
complied with, then the employee, the school district or school, and the members of the governing
board shall not be liable in any criminal action or for civil damages as a result of the administration
of the medication.
RCW 28A.210.260 makes no distinction between prescription and non-prescription medication. The
Office of Superintendent of Public Instruction (OSPI) has interpreted the statute to include over the
counter (OTC) medications. For the administration of any medication, prescription or OTC, the
school is required to obtain a “written, current, and unexpired request” from a LHP prescribing
within the scope of their prescriptive authority for the administration of that medication (RCW
28A.210.260). OSPI Bulletin No. 34-01 The Administration of Medications in Schools (2001).
The following is an outline of the statutory conditions.
Public and Private Schools—Administration of
Medication—Conditions
RCW 28A.210.260
General Provisions
Public school districts and private schools conducting kindergarten through twelfth grade may
provide for the administration of oral medication, topical medication, eye drops, ear drops, or nasal
spray of any nature to students who are in the custody of the school district or school at the time
of administration but are not required to do so. Each school board shall seek advice from at least
one licensed physician or registered nurse in developing policies.
School board policies shall address:
1. Designation of employees who may administer oral medications, topical medications, eye
drops, ear drops, or nasal spray to students.
2. Acquisition of medication requests and instructions (authorization) from parent or legal
guardian.
3. Acquisition of medication requests and instructions from licensed health care providers
(LHP), prescribing within the scope of their prescriptive authority.
4. The identification of the medication to be administered.
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5. The means of safekeeping medications with special attention given to the safeguarding of
legend drugs as defined in RCW 69.41.
6. The means of maintaining a record of the administration of such medication.
The board of directors shall designate a professional person licensed pursuant to RCW 18.71 or
RCW 18.79 as it applies to registered nurses and advanced registered nurse practitioners, to
delegate to, train, and supervise the designated school district personnel in proper medication
procedures.
The public school district or private school is in receipt of a written, current, and unexpired request
(authorization) and instructions to administer the medication from:
• A parent or legal guardian.
• A licensed health care provider (LHP), prescribing within the scope of their prescriptive
authority for administration of the medication, as there exists a valid health reason which
makes administration of such medication advisable during the hours when school is in
session or the hours in which the student is under the supervision of school officials.
• Written, current and unexpired instructions from such licensed health professional
prescribing within the scope of their prescriptive authority regarding the administration of
prescribed medication to students who require medication for more than fifteen
consecutive workdays.
**Note: The statute requires an LHP medication request (authorization) regardless of how long the
medication is to be administered and requires additional instructions regarding the administration of
the medication from the LHP if the medication is required for more than 15 consecutive workdays.
A. The medication is administered by an employee designated by or pursuant to the school
board policies and in substantial compliance with the prescription and instructions of an
LHP prescribing within the scope of their prescriptive authority.
• The medication is first examined by the employee administering it to determine in their
judgment that it appears to be in the original container and to be properly labeled.
• The board of directors shall allow school personnel, who have received appropriate
training and volunteered for such training, to administer a nasal spray that is a legend
drug or controlled substance as delegated by the school nurse.
B. The board of directors shall designate a professional person licensed under RCW 18.71,
18.57, or 18.79 as it applies to RNs or ARNPs, to consult and coordinate with the student’s
parents and LHP, and train and supervise the appropriate school staff in proper procedures
for care for students with epilepsy to ensure a safe, therapeutic learning environment.
Training may also be provided by an epilepsy educator who is nationally certified.
C. A “parent-designated adult” (PDA) means a volunteer, who may be a school district
employee, who receives additional training from a health care professional or expert in
epileptic seizure care selected by the parents, and who provides care for the child
consistent with the individual health plan. Training may also be provided by a national
organization that offers training for school nurses for managing students with seizures and
seizure training for school personnel starting in the 2022–23 school year. See also RCW
28A.210.355 Students with Epilepsy or other Seizure Disorders and RCW 28A.210.330
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Students with Diabetes.
• To be eligible to be a PDA, a school employee, not licensed under RCW 18.79 must file,
without coercion by the employer, a voluntary written, current, and unexpired letter of
intent stating the employee’s willingness to be a PDA.
• If the non-licensed school employee chooses not to file a letter, the employee shall not
be subject to any employer reprisal or disciplinary action for refusing to file a letter.
• PDAs who are not school employees must show evidence of comparable training.
• The PDA must also receive additional training for the care the parents have authorized
the PDA to provide.
• The professional person (RN/ARNP) is not responsible for the supervision of the PDA for
those procedures that are authorized by the parents.
Note: Specific laws allow Parent Designated Adults for diabetes and epilepsy or seizure
disorders only.
Public and Private Schools—Administration of
Medication—Immunity from Liability—Discontinuance,
Procedure
RCW 28A.210.270
General Provisions
A. A school district employee not licensed under chapter RCW 18.79 who is asked to
administer medications or perform nursing services not previously recognized in law, shall
at the time he or she is asked to administer the medication or perform the nursing service,
file without coercion, by the employer, a voluntary written, current, and unexpired letter of
intent, stating the employee's willingness to administer the new medication or nursing
service. It is understood that the letter of intent will expire if the conditions of acceptance
are substantially changed. If a school employee who is not licensed under chapter RCW
18.79 chooses not to file a letter under this section, the employee is not subject to any
employer reprisal or disciplinary action for refusing to file a letter.
B. In the event a school employee provides the medication or service to a student in
substantial compliance with (a) rules adopted by the Washington State Nursing Care
Quality Assurance Commission, and the instructions of a registered nurse or advanced
registered nurse practitioner issued under such rules, and (b) written policies of the school
district, then the employee, the employee's school district or school of employment, and
the members of the governing board and chief administrator thereof are not liable in any
criminal action or for civil damages in their individual, marital, governmental, corporate, or
other capacity as a result of providing the medication or service.
C. The board of directors shall designate a professional person licensed under chapter RCW
18.71 or RCW 18.79 as it applies to registered nurses and advanced registered nurse
practitioners to consult and coordinate with the student's parent/guardian and health care
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provider, and train and supervise the appropriate school district personnel in proper
procedures to ensure a safe, therapeutic learning environment. School employees must
receive the training provided under this subsection before they are authorized to deliver the
service or medication. Such training must be provided, where necessary, on an ongoing
basis to ensure that the proper procedures are not forgotten because the services or
medication are delivered infrequently.
WASHINGTON STATE NURSING PRACTICE:
ARNP, RN, AND LPN
In Washington, nurses working in schools may be either an Advanced Registered Nurse Practitioner
(ARNP), registered nurse (RN), or a licensed practical nurse (LPN) as defined in RCW 18.79.
Per WAC 246-840, there is a difference in the educational preparation and scope of practice
between the ARNP, RN and LPN as summarized below:
• Advanced Registered Nurse Practitioner (ARNP): It is within the scope of practice of the
ARNP to provide primary healthcare services to students in accordance with WAC 246-840-
300. The ARNP may also perform acts within the scope of registered nursing practice.
• Registered Nurse (RN) Practice: According to WAC 246-840-705, the RN, using
specialized knowledge, can perform the activities of administration, delegation, supervision,
and evaluation of nursing practice. The RN functions in an independent role when utilizing
the nursing process. The RN functions in an interdependent role when executing a medical
regimen under the direction of an LHP.
• Licensed Practical Nurse (LPN) Practice: RCW 18.79.270 identifies activities within an
LPN’s scope of practice. LPNs may perform nursing care and carry out medical regimens,
including administering medications by any route under the direction of a licensed
physician and surgeon, osteopathic physician and surgeon, dentist, naturopathic physician,
podiatric physician and surgeon, physician assistant, osteopathic physician assistant,
advanced registered nurse practitioner, or midwife acting under the scope of their license or
at the direction and under the supervision of a registered nurse. The LPN must have the
training, knowledge, skill, and ability to perform the activity competently. An LPN
recognizes and meets basic student needs in routine nursing situations that are relatively
free of complexity involving stable and predictable student conditions. LPNs also function in
more complex nursing care situations, and in these cases an LPN would function as an
assistant to the RN. LPNs can participate with the RN in revising the care plan and deliver
the care according to the plan. LPNs may not delegate nursing tasks to unlicensed staff in
the school setting. LPNs are not licensed for independent nursing practice; therefore, may
not practice without supervision of nursing care provided to students by at least an RN.
Supervision of the LPN by the RN does not necessarily mean an LHP or RN has to be on the
premises. WAC 246-840-010 defines supervision as:
• Provision of guidance and evaluation for the accomplishment of a nursing task or activity
with the initial direction of the task or activity
• Periodic inspection of the act of accomplishing the task or activity
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• The authority to require corrective action
LPNs are fully licensed health professionals and are accountable and responsible for their own
actions and do not “work under” the RN’s license or through the delegation process.
REGISTERED NURSE DELEGATION IN THE
SCHOOL SETTING
Provisions of the Nursing Care Delegation Statute and
Regulations
RCW 18.79.260 addresses the activities for delegation of registered nursing tasks.
WAC 246-840-010 describes delegation as:
“Delegation means the… registered nurse transfers the performance of selected nursing tasks to
competent individuals in selected situations. The … registered nurse delegating the tasks retains the
responsibility and accountability for the nursing care of the client. The … registered nurse delegating
the task supervises the performance of the unlicensed person.
(a) Nursing acts delegated by the …registered nurse shall:
(i) Be within the area of responsibility of the …registered nurse delegating the act.
(ii) Be such that, in the opinion of the …registered nurse, it can be properly and safely performed
by the unlicensed person without jeopardizing the patient welfare.
(iii) Be acts that a reasonable and prudent …registered nurse would find are within the scope of
sound nursing judgment.
(b) Nursing acts delegated by the …registered nurse shall not require the unlicensed person to
exercise nursing judgment nor perform acts which must only be performed by a licensed
…registered nurse, except in an emergency situation.
(c) When delegating a nursing act to an unlicensed person it is the registered nurse who shall:
(i) Make an assessment of the patient's nursing care need before delegating the task;
(ii) Instruct the unlicensed person in the delegated task or verify competency to perform or be
assured that the person is competent to perform the nursing task as a result of the systems in
place….
(iii) Recognize that some nursing interventions require nursing knowledge, judgment, and skill
and therefore may not lawfully be delegated to unlicensed persons.”
Delegation Recommendations from Nursing Care
Quality Assurance Commission (NCQAC)
The principles and process of delegation are defined in RCW 18.79.260. Delegation in the school
setting is further described in the
DOH NCQAC Advisory Opinion, Registered Nurse Delegation in
School Settings Number NCAO 4.0 as summarized below.
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Principles of Delegation
A RN delegating in a school setting:
• Takes responsibility and is accountable for providing nursing care.
• Directs the care and determines whether delegation is appropriate.
• Delegates specific tasks but not the nursing process.
• Uses nursing judgment concerning a student’s condition, the competence of the UAP,
and the degree of supervision required prior to delegation.
• Delegates only those tasks where the UAP has the knowledge, skill, and ability to
perform the task safely.
• Communicates and verifies comprehension and acceptance of delegation and
responsibility.
• Provides opportunities for the UAP to ask questions and clarify expectations.
• Uses critical thinking and professional judgment when following the Five Rights of
Delegation:
o Right task - task is appropriate to be delegated.
o Right circumstances-appropriate setting and necessary resources.
o Right person-right task for the right student.
o Right directions and communication.
o Right supervision and evaluation.
• Establishes systems to assess, monitor, verify, and communicate ongoing competency
requirements in areas related to delegation.
Delegation Process
1. Use the School Registered Nurse Delegation Decision Tree (see appendix) to determine
whether delegation of a nursing task is appropriate.
2. Perform nursing assessment of the student’s health care needs; consider available resources
and unique factors that could make outcomes of the delegated task unpredictable, such as
whether:
• There is a nurse available or able to provide care on a regular basis.
• The student’s health care needs are stable, uncomplicated, routine, and predictable.
• The environment is conducive to delegation.
• The student is unable to provide self-care.
• The task does not require use of nursing judgment.
3. Develop a plan to provide periodic re-training and re-demonstration of competency.
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4. Perform periodic inspection and evaluation and take corrective action as needed.
5. Delegate only in accordance with the RN’s education, training, knowledge, skills and
experience (seek consultation from another RN if necessary).
6. Assess the UAP’s willingness and potential ability to perform the task for the individual
student:
• Consider psychomotor and cognitive skills required to perform the nursing task.
• Verify that the UAP is willing to perform the task in the absence of direct or immediate
nurse supervision and has signed the letter of intent if applicable. *NOTE: The above
statement relates to RCW 28A.210.275. In addition, RCW 28A.210.255 directs that any
employee of a public school district or private school that performs health services, such
as catheterization, must have a job description that lists all of the health services that
the employee may be required to perform for students. This would also include
medication administration.
• Analyze the complexity of the nursing task to determine required or additional training
needed by the UAP to competently accomplish the task.
• Assess the level of interaction required, considering language or cultural diversity, that
may affect communication or the ability to accomplish the task to be delegated, as well
as methods to facilitate the interaction.
7. Provide or verify training and competency assessment for the UAP (consider using
standardized training modules and assessment processes).
8. Provide clear and specific instructions to the UAP including when and how to contact the
RN delegating the care or back-up RN.
9. Implement and evaluate delegation:
• Supervise and evaluate the UAP’s performance on a periodic basis (the method and
frequency of supervision and evaluation is at the discretion of the RN delegating the
care).
10. Document the delegation process and adherence according to school or school district
policies.
11. Notify district administration if it is not safe to delegate a particular nursing task and of the
potential need for the district to provide nursing services rather than providing the care
through delegation to a UAP.
Documenting Delegation
The delegating RN should document the delegation process regardless of the documentation
system used including:
• Instructions for the task should be specific and broken into individual components.
• Document specific steps for the delegated task (consider a system where the RN and UAP
initial each step).
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• Document dates, training, and competency assessment including RN and UAP signatures
Rescinding Delegation
RNs delegating care retain the authority to rescind delegation when the following occur:
• A significant change or decline in the student’s health status that would make delegation
unsafe.
• The UAP lacks sufficient training, knowledge, skills, or ability to perform a task safely and
competently, or is unwilling.
• A determination that the specific task requires nursing judgment.
• There is a change in school nurse or UAP assignment.
• The RN is no longer employed by the school.
• The RN is no longer under contract (for example during summer school).
• Student transfers to a different school or district.
In such cases the delegating RN should initiate and participate in developing an alternative plan to
ensure continuity. Rescission of delegation and actions should be documented.
Transferring Delegation
Delegation authority cannot be transferred from one RN to another. If the delegating RN is no
longer assigned to a student or group of students, the RN assuming authority must undertake new
delegation to the UAP.
RN Delegation Considerations
The RN may need to clarify the process of nursing delegation to school administrators.
• RNs cannot be coerced into delegation. The nurse practice act, RCW 18.79.260 stipulates
that: “No person may coerce a nurse into compromising patient safety by requiring the
nurse to delegate if the nurse determines that it is inappropriate to do so. Nurses shall not
be subject to any employer reprisal or disciplinary action by the Nursing Care Quality
Assurance Commission for refusing to delegate tasks or refusing to provide the required
training for delegation if the nurse determines delegations may compromise patient safety.“
• The RN cannot delegate:
o To volunteers, parents/guardians, or non-school employees during school or during
school sponsored events.
o Acts requiring substantial skill.
o Piercing or severing of tissues (except for emergency use of epinephrine injections).
o Acts requiring nursing judgment.
o Injections (except for epinephrine for anaphylaxis).
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o Sterile procedures.
o Central line maintenance.
o Nasogastric (NG) tube procedures as per RCW 18.79.260.
o Rectal Medication as per RCW 28A.210.260.
• UAPs are responsible to comply with the nursing plan, obtain guidance as needed, and
report changes to the RN. If a UAP does not follow the plan or direction, the RN may need
to provide further training and supervision. If safety is compromised, delegation may need
to be rescinded.
• The RN may be held accountable for standards of practice related to delegation and may
be subject to disciplinary action per RCW 18.79.260 and WAC 246-840-700:
o Delegating nursing care function or responsibilities to a person the nurse knows or
has reason to believe lacks the ability or knowledge to perform the function or
responsibility.
o Delegating to unlicensed persons those functions or responsibilities the nurse
knows are to be performed only by licensed persons.
o Failure to supervise those to whom nursing activities have been delegated; or
o The supervision must be adequate to prevent an unreasonable risk of harm to
clients.
School District Considerations
Responsibility for appropriate registered nurse delegation ultimately rests with the school district
to ensure safe nursing care is provided to students. This would include availability of a licensed
nurse to administer medications and treatments that cannot be delegated by law or per the
registered nurse’s professional judgment.
RCW 28A.210.260 states: The Board of Directors shall designate a professional person licensed
pursuant to RCW 18.71 or RCW 18.79 as it applies to registered nurses and advanced
registered nurse practitioners, to delegate to, train, and supervise the designated school
district personnel in proper medication procedures.
RCW 18.79.030 requires a license for nursing practice:
“It is unlawful for a person to practice or to offer to practice as a registered nurse in this
state unless that person has been licensed under this chapter. A person who holds a
license to practice as a registered nurse in this state may use the titles “registered
nurse” and “nurse” and the abbreviation “R.N.” No other person may assume those
titles or use the abbreviation or any other words, letters, signs, or figures to indicate
that the person using them is a registered nurse.”
WAC 181-87-070 addresses unprofessional practice as described by the Professional Educator
Standards Board:
“Any act performed without good cause that materially contributes to one of the
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following unauthorized professional practices is an act of unprofessional practice...The
assignment or delegation in a school setting of any responsibility within the scope of
the authorized practice of nursing, physical therapy, or occupational therapy to a
person not licensed to practice such profession, unless such assignment or delegation is
otherwise authorized by law including the rules of the appropriate licensing board.”
School Delegation: School Decision Tree
The DOH NCQAC Advisory Opinion includes the school nurse delegation decision tree tool. This
tool may be useful for school nurses tin determining if and when to delegate. Registered Nurse
Delegation in School Settings: Kindergarten-Twelve (K-12) Grades, Public and Private Schools –
Nurse Delegation Tree Tool NCQAC Advisory Opinion NCAO 15.01 (wa.gov)
.
TRAINING OF UNLICENSED ASSISTIVE
PERSONNEL IN THE ADMINISTRATION OF
MEDICATION
The delegating RN is responsible for ongoing training, competency, evaluations, and supervision of
the UAP with appropriate documentation of the entire training process.
Medication statutes require that all UAPs designated by district policy to administer medications, are
to be delegated to, trained, and supervised by a professional person licensed pursuant to chapter
18.71 RCW or chapter 18.79 RCW, as it applies to RNs or ARNPs.
Prior to the beginning of a new school year, district administration or building principals, in
consultation with the RN, identify in writing at least two staff persons per building to administer
medications for the coming school year. These individuals shall receive training in the following prior to
administering medications to students:
A. Washington state statutes and school board policies and procedures governing the
administration of medications.
B. Medication administration procedures, including description of when not to administer a
medication.
C. Procedures to follow in the event of a medication error, including missed or delayed doses.
D. Required charting.
E. When to contact the supervising nurse.
F. Confidentiality issues regarding the administration of medications and student health
information.
The supervising RN will evaluate the UAP's skill, document the completion of the training, and
determine the degree of supervision necessary and provide that supervision.
For th
e district to receive the immunity from liability based upon substantial compliance with the
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statutes, the UAP must be delegated to, trained, and supervised by a RN, ARNP, or physician (MD).
Please see the Washington State School Staff Health Training Guide
.
For additional resources, see Section XVIII References
ROUTES OF MEDICATION ADMINISTRATION
The Washington state medication statute RCW 28A.210.260 addresses oral medication, topical
medication, eye drops, ear drops and nasal spray. Medications administered by other routes (rectal,
nasogastric tube, injection etc.) are not covered under this statute and are regulated by the law
relating to nursing care, RCW 18.79.260. The appendices include skills checklists for each of the
following routes of medication administration.
Oral Medication (by mouth, gastrostomy tube, inhaled)
Oral medications (by mouth) include solid forms such as tablets or capsules, and liquid forms such
as syrups/elixirs and suspensions. Oral medication should not be altered (i.e. cut, crushed or
sprinkled on food) without an LHP’s order.
Enteral medication (by gastrostomy tube) is considered an oral medication as it is administered
directly into the digestive tract. An RN may delegate medication given via gastrostomy tube
following delegation procedures.
Inhaled Medication is considered an oral medication whether or not the medication is given by
mask or with a spacer that covers the mouth or mouth and nose. It can come in the form of a multi
dose inhaler or nebulizer treatment. Intranasal medication is not included in this description.
Nasal Spray
Nasal spray delivers medication as a spray directly into the external nares (nostrils). It may be a
powder or liquid spray.
Topical Medication
Topical medication is applied locally to skin or mucous membranes and is absorbed directly
through the skin into the blood stream. It can come in the form of a lotion, ointment, patch, cream
or paste.
Eye Drops
Eye drops are medications that are instilled in the eye and are absorbed quickly due to the
membrane’s vascularity.
Ear Drops
Ear drops are medications that are instilled directly into the outer ear canal.
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Injection
The only injection that RNs may delegate to UAP in the school setting is epinephrine per RCW
18.79.240(1) (b) and (2) (b) and district policy and procedure.
NURSING PRACTICE AND BOARD OF
PHARMACY RECOMMENDATIONS
Licensed Healthcare Providers (LHP) Who May Prescribe
and Administer Medications
A nurse administers medications, treatments, tests and other nursing care RCW 18.79.260(2) at or
under the general direction of an LHP including: licensed physician and surgeon, dentist,
osteopathic physician and surgeon, naturopathic physician, optometrist, podiatric physician and
surgeon, physician assistant, osteopathic physician assistant, advanced registered nurse practitioner
(ARNP), or midwife acting within the scope of their license. All prescriptions must be for a valid
legitimate medical purpose and there must be a valid doctor-patient relationship. Prescriptions
must be written within the practitioner’s scope of practice RCW 69.41.030 and RCW 69.50.101 (ee)
(3).
Out of State Prescriptions
RCW 69.41.030 reads: Sale, delivery, or possession of legend drugs without prescription or order
prohibited-Exceptions-Penalty.
Prescriptions written for legend drugs, including controlled substances, by the following prescribers
licensed in any state of the United States may be dispensed by a Washington
pharmacist/pharmacy: physicians licensed to practice medicine and surgery, physicians licensed to
practice osteopathic medicine and surgery, dentists licensed to practice dentistry, podiatric
physicians and surgeons licensed to practice podiatric medicine and surgery, licensed advanced
registered nurse practitioners, licensed physician assistants, and licensed osteopathic physician
assistants.
Prescriptions written for legend drugs, not including controlled substances may also be dispensed
by a Washington pharmacist/pharmacy if written by any of the above practitioners, licensed to
practice in British Columbia.
Who Can Prescribe and Administer Prescriptions - Washington State
Department of Health
Receipt of Medication
• Medications that the parent/guardian and the LHP authorize to be administered should be
brought to school by the parent/guardian of the student or by another designated adult.
There may be an exception made for medications that are self-administered by students such as
epinephrine auto-injectors or asthma inhalers if this is supported by district policy and/or procedure.
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• All medications must be in properly labeled medication containers with name of the
medication, student name, date, quantity, and strength per dosage unit, LHP name, frequency
of administration, and other instructions for giving medications.
• Written and signed parent/guardian and LHP authorization requests are required for all
medications to be administered by school staff. For medications given more than 15 days,
more specific LHP instructions are required in addition to those listed above.
• All medication should be counted by school staff and the parent/guardian or designated
adult who brought it to school. The number of pills, tablets, capsules, or amount of liquid,
etc., should be recorded on the medication administration record or districts may choose to
document on a separate form designed specifically for this purpose.
• If a tablet must be divided to obtain the correct dose, the pharmacist should be asked to
divide the tablet when filling the prescription. If this is impractical, there are specialized
devices to assist with cutting the tablets. Districts should follow their policy/procedure
regarding school staff cutting the tablets.
• Parent/guardian may request the pharmacist prepare a school container for medication and
a container for home. It is also helpful to request an additional (3
rd
) bottle to be used for
field trips.
Inventory of Medication
Routine counting of medications should occur based on the district’s policy and procedure.
Controlled substances-scheduled drugs
(e.g. cough syrup with codeine or Ritalin) should be
counted weekly and recorded. On the weekly medication counts, the nurse or designee needs to
have a witness to the actual count of the medications. It may be helpful for the district to purchase
pill counting trays.
It is recommended that no more than a twenty-day supply of controlled substances-Schedule II-V,
be brought to the school at any one time.
Theft or suspected theft is to be documented and reported to the supervising nurse, the school
administrator and may also be reportable to local law enforcement.
Storage and Security of Medication
• Medications should be stored in locked, substantially constructed cabinets or drawers, with
access limited to those who will need access when medications are received or to
administer medications. *NOTE: Emergency medications must be readily available.
• Examples of substantially constructed cabinets:
1. Commercially manufactured safes.
2. Commercially manufactured drug security units made of heavy gage metal that are
attachable to a wall or floor with single or double-locking mechanism.
3. Non-commercially made cabinets made of metal, solid wood 0.5” thick, or plywood
0.75” thick with non-exposed hinges or non-removable hinge pins if hinges are
exposed.
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4. A metal filing cabinet with a metal bar capable of being locked into position, blocking
the opening of the drawers. It should be secured to the floor/wall or weighted
sufficiently to prevent theft of the entire cabinet.
• The number of keys to the locked storage is recommended to be no more than two keys.
The keys should be specific to that cupboard/drawer and not unlock any other area in the
school.
• It is recommended that Schedule II – V controlled substances be placed in the school safe
during school holidays, weekends, summer, etc.
• The district’s policy/procedure should address theft of medications and describe the
reporting process. Districts may want to discuss with local law enforcement to determine if
or when the loss of controlled substances should be reported.
Medication Administration Responsibilities
It is the school’s responsibility to ensure that medications are administered as authorized by the
parent/guardian and LHP.
Student not Reporting for Medication
When students do not appear at the scheduled time for their medication, school personnel remain
responsible for timely administration of the dose and should have a plan for handling “no show”
students.
Student Refusal of Medication
If a student refuses a medication, the RN and the parent/guardian will be notified as soon as
possible and documented on the medication administration record as a “refused” medication. The
documentation assures the student has been offered the medication as ordered and proves staff
followed school district policy in administration/documentation. As best practice and according to
the student’s developmental level, the student should understand why the medication is being
administered and should be made aware of any common side effects. He/she should also be able
to verbalize understanding that these medications are considered a part of treatment. The RN
needs to communicate and address student refusal of medication with parent/guardian and their
LHP.
Early Dismissal and Medication Administration
Procedures should be in place to address early school dismissal before a regularly administered
medication is to be given.
Changes in the Student’s Medication Order
Whenever there is a change in the medication order, a new medication request form is created. The
UAP must contact the RN immediately if a change in a medication order is received or guidance is
needed.
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If there is a dosage change, only a licensed nurse can take the verbal/phone/fax order from the
LHP or the LHP’s support staff. The verbal order must be followed by the written order within a
reasonable period of time. Faxed orders are considered written orders, but the licensed nurse must
be confident that they came from the ordering LHP. The medication container with the previous
prescription label may be used for up to 10 school days to give parent/guardian time to get a
bottle with a current order as long as the nurse has a current order and directs the UAP to use the
available container with clear instructions so that the correct dose is administered.
All new medication orders need to be reviewed and approved by the RN, necessary forms for
documentation prepared, and training and delegation completed, prior to school staff
administering the first dose.
Expired Medications
Drugs that fail to meet the compendial standards are considered adulterated drugs. This includes
expired medications. If a medication is expired, it may fail to meet the compendial drug standard,
which may impact the quality of the medication. In 1979, the U.S. Food and Drug Administration
(FDA) began requiring an expiration date on prescription and over-the counter medicines. The
expiration date is a critical part of deciding if the product is safe to use and will work as intended.
Schools should not accept medications that are expired unless there has been a notification from
the FDA with an exception for that medication at that time. See RCW 69.04.420 Drugs—
Adulteration for failure to comply with compendium standard and RCW 69.04.430 Drugs—
Adulteration for lack of represented purity or quality.
Documentation
Documentation is very important when medication is given at school. Standards of nursing
documentation need to be followed whether you are using paper or an electronic documentation
system. A medication request form and medication administration record (MAR) or “medication
log” must be kept for each student. The medication request form and medication administration
record contain the student’s name, the prescribed medication, the dosage, the route the
medication is to be given, the time the medication is scheduled to be given, and any student
allergies.
Compare the information on the medication container label with the information on the
medication request and medication administration record. This information must match. The
medication should not be given if the information does not match, or the medication label is
missing, or the label cannot be read.
When and how to document:
• Immediately after giving the medication; not before.
• Only document medication that you administer.
• Record initials, date, and exact time of medication administered in the designated box on
the medication administration record (MAR).
• Write your initials next to your name one time on the MAR so that you can be identified.
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• When initialing on the medication administration record be sure not to circle your initials
unless there was an issue that needs to be further addressed such as a missed dose. Circled
initials usually indicate that there was some sort of problem.
• Be sure to document when a medication is missed due to an absence or a field trip or if the
student refuses to take the medication.
• Note unusual behaviors/occurrences that were observed after student received medication.
• Use black or blue ink, never pencil.
Other documentation considerations:
• If a charting error occurs, draw a single line through the mistaken entry, initial and date
error, and explain on the back of the MAR (never use white-out, erase, or scratch it out).
• If the medication cannot be given, falls to the floor, or the student refuses a medication,
initial the appropriate box, provide an explanation on the back of the MAR and notify the
appropriate person as outlined in your school procedures.
• If medication is discontinued write “discontinued,” on the page as close to the date as
possible and initial it. Ask parent/guardian to pick up any remaining medication.
• The registered nurse is responsible for the transcription of medication administration
information onto the MAR. When creating a new MAR, it is important to transcribe from the
current LHP orders, and not from the old or previous MAR.
• When documenting the administration of PRN (as needed) medication, record the time
given and the dosage, if applicable.
• The medication administration record may also be used to make notes about any unusual
circumstance related to the student receiving the medication, including contact with LHP
and/or parent/guardian.
Record Retention Requirements
The medication administration record is a part of the student’s file and provides legal
documentation for those who administer medications to students. Records may include but are not
limited to medication/treatment authorization form, MAR, and medication administration incident
report form. These records should be retained for 8 years after last entry/dose or matter is
resolved, whichever is later; then destroyed.
If the district uses a separate medication inventory and/or disposal form, retain for 1 year after
medication is returned/destroyed/delivered to outside agencies; then destroy.
For more information about record retention, see the June 2020 Public Schools Records Retention
Schedule which covers student health records for pre-kindergarten through grade 12.
Confidentiality and Privacy
All information regarding a student’s health status and their medication is confidential, and without
parent/guardian (or student if applicable), permission cannot usually be discussed by UAP
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administering medication with anyone except the delegating nurse. Students are entitled to
privacy during the administration of their medication.
Per RCW 70.02.050, a healthcare provider may disclose health care information—except for
information and records related to sexually transmitted diseases—about a patient without the
patient’s authorization to the extent a recipient needs to know the information, if the disclosure is
to a person who the provider reasonably believes is providing health care to the patient.
Confidentiality is a very important legal concept in the school setting. The
Family Educational
Rights and Privacy Act (FERPA) is a federal law that protects the privacy interests of students and
their educational records. FERPA applies to any educational agency that receives funds from the
United States Department of Education (USDOE). Health records (including medication documents)
maintained by school employees for pre-kindergarten through grade twelve students are
considered education records and therefore protected by FERPA.
The Health Information Portability and Accountability Act (HIPAA) of 1996 Privacy Rule requires
covered entities to protect individuals’ health records and other identifiable health information.
When schools provide health care to students in the normal course of business, it is also known as
a “health care provider”. The HIPAA Privacy Rule allows covered health care provider to disclose
protected health information about students to school nurses, physicians, or other health care
providers for treatment purposes, without the authorization of the student or student’s parent. See
Joint Guidance on the Application of FERPA and HIPAA to Student Health Records | Protecting
Student Privacy (ed.gov)
Discontinuing Medication
As stated in RCW 28A.210.270 (2), “The administration of oral medication, topical medication, eye
drops, ear drops, or nasal spray to any student pursuant to RCW 28A.210.260 may be discontinued by
a public school district or private school and the school district or school, its employees, its chief
administrator, and members of its governing board shall not be liable in any criminal action or for
civil damages in their governmental or corporate or individual or marital or other capacities as a
result of the discontinuance of such administration: PROVIDED, That the chief administrator of the
public school district or private school, or their designee, has first provided actual notice orally or in
writing in advance of the date of discontinuance to a parent or legal guardian of the student or other
person having legal control over the student.”
Before a medication is discontinued, districts need to be aware that under the federal civil rights
legislation, administration of medication in school may be a related service that must be provided if
the student qualifies for 504 accommodations. There must be a valid reason that does not
compromise the health of the student to discontinue medication administration. See
U.S.
Department of Human and Health Office of Civil Rights Fact Sheet: Your Rights Under Section 504
of the Rehabilitation Act.
If a parent/guardian chooses to discontinue a medication at any time, it is recommended that the
request be in writing. If the medication is for a life-threatening health condition, RCW 28A.210.320,
requires that the medication or treatment be in place for the student to attend school.
Discontinuation of the medication may put the student at risk. The RN in this instance should
discuss the request to discontinue the medication not only with the parent/guardian but also with
the LHP. District policy may require written documentation of LHP and parent/guardian permission
Page | 26
to discontinue the medication. If the medication/treatment is not for a life-threatening condition, it
is still prudent practice for the RN to notify the LHP that the parent/guardian has requested the
medication/treatment be discontinued.
Disposal of Medication
At least two weeks prior to the end of the school year, or when a medication is discontinued,
parent/guardian of students with leftover medication should be notified in writing and provided
the opportunity to pick up any unused medication.
If parent/guardian does not pick up the medication by the date specified, the medication should be
counted by two school district staff and properly disposed. Documentation should include the
name of the medication, the amount of medication to be disposed, the date and signatures of two
staff members (recommend one staff be the school nurse) witnessing the disposal.
FDA disposal considerations:
• Follow any specific disposal instructions on the prescription label or patient information that
accompanies the medication. Do not flush prescription drugs down the toilet unless
otherwise directed by FDA disposal guidance.
• Sharps and medical waste disposal guidelines may vary from county to county. For further
guidance, contact the district facilities manager or your local health jurisdiction, pharmacy,
waste management, police, or fire station. Some districts contract with a waste disposal
company.
• Take advantage of community drug take-back programs that allow the public to bring
unused medications to a central location for proper disposal. Call your city or county
government’s household trash and recycling service to see if a take-back program is
available in your community.
• Take the medication out of the original container and mix with an undesirable substance,
such as used (wet) coffee grounds or kitty litter. The medication will be less appealing to
children and pets, and unrecognizable to people who may intentionally go through your
trash. Put medication in a sealable bag or other container to prevent the medication from
leaking or breaking out of a garbage bag.
• Depending on the type of product and where you live, inhalers and aerosol products may
be thrown into the trash or recyclables or may be considered hazardous waste and require
special handling. Read the handling instructions on the label, as some inhalers should not
be punctured or thrown into a fire or incinerator.
• Prefilled syringes: the medication in the syringe may be disposed of as indicated above. If
there is a needle on the empty syringe it should be placed in a sharps container (Note: do
not remove needle from syringe or attempt to re-cap). Expired or used epinephrine auto-
injectors are considered hazardous medical waste and need to be disposed of safely. The
auto injectors should be left in their original plastic container and put into a sharps or bio-
hazard container for disposal.
• When in doubt about proper disposal, consult with the pharmacist.
• Before discarding a medication container, scratch out all identifying information on the
Page | 27
prescription label to make it unreadable. This will help protect the students’ identity and the
privacy of their personal health information.
Medication Error
The correct medications must be administered to the correct student at the correct time (within 30
minutes before or after the prescribed dose is ordered) in the correct dosage, by the correct route,
with accurate documentation. Deviation from this standard may constitute a medication error. A
dose that is missed (omitted) for whatever reason may also be considered a medication error. All
medication errors must be documented and reported to the nurse who provides supervision for the
UAP giving the medications for the school under RCW 28A.210.260 and 28A.210.270.
Analysis of the reports will be completed at least annually to determine any systems modifications
that are necessary. This analysis will be reported to the school building administrator and forwarded
to the district administration with recommendations.
Recommended medication error procedures:
• All errors must be documented and reported to the supervising nurse for the school within 24
hours. Serious errors must be reported immediately to the supervising nurse.
• The supervising nurse, using clinical judgment, will determine the level of severity of the
medication error.
• If the error is committed by a licensed provider, and there is injury to the student, or causes the
student to be seen by emergency services, the incident must be reported by the supervising
nurse to:
o L
HP
o Parent/guardian
o School administrator
o The Washington State Nursing Care Quality Assurance Commission, WAC 246-840-730
PO Box 47864, Olympia, WA 98504-7864, (360) 236-4700.
• If the error is committed by a UAP and there is injury to the student, or causes the student to be
seen by emergency services, the incident must be reported by the supervising nurse to:
o LHP
o Parent/guardian
o School administrator
o The Washington State Department of Health, Unlicensed Practice Unit (360-236-
4718). There may be administrative actions or fines.
• All actions taken as a result of the medication error are to be accurately documented.
• Medication administration incident reports will be maintained for eight years after the
incident.
• The supervising nurse should assess the actions taken in response to medication errors. The
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completed reports will be used by the supervising nurse to:
o Determine trends and patterns in medication errors.
o Assist in identification of educational and resource needs of licensed and unlicensed
staff (e.g. UAPs).
o Record circumstances contributing to the error and actions taken as a result of the
error.
*NOTE: Refusing medication is not considered a medication error and the refusal should be
documented on the Medication Administration Record as a “refused” medication and reported to
the supervising RN and parent/guardian as soon as it is possible.
The above information came from the “Guidance from Washington State Nursing Care Quality
Assurance Commission Policy Statement Oral Medication Error Reporting in Schools”, May 2001
per NWESD 189”. This document is archived by the Nursing Care Quality Assurance Commission
and is not available on their website.
STUDENT SELF-ADMINISTRATION OF
MEDICATION
Self-administration of medication in schools refers to situations in which students carry their own
medication and administer that medication to themselves. There are instances in which an LHP
and parent/guardian may request that a student be permitted to carry their own medication
and/or to self-administer the medication. Student self-administration of medication is not within
the purview of RCW 28A. 210.260 Public and private schools - Administration of Medication-
Conditions. However, there are other specific situations in which students may be allowed to self-
carry and administer medication.
Asthma, Anaphylaxis and Diabetes Medication
RCW 28A.210.370 and RCW 28A.210.330 include language for self-administration of medication for
students with asthma, anaphylaxis, and diabetes.
Considerations:
• All districts are required to adopt policies and procedures and must grant permission for
students to self-carry medications under specific circumstances as outlined in the statutes.
• An LHP has provided a written medication authorization signed by the parent/guardian for
granting permission for self-administration of the medication during school and school
sponsored events, including transportation.
• Student has been instructed in the correct and responsible use of the medication.
• The student has demonstrated to the LHP or designee and the RN at the school, the skill level
necessary to use the medication and any device necessary to administer the medication as
prescribed.
• The LHP formulates a written treatment plan for medication/treatment use by the student.
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• The student’s parent/guardian has completed and submitted to the school any additional
written documentation the school requires.
• If a backup medication is supplied by the parent/guardian, it must be kept in a location where
the student has immediate access in the event of a medical emergency. The student should
also have easy access to any related supplies or equipment provided by the parent/guardian.
Other Medication
Student self-administration of medication other than those for asthma, anaphylaxis, and diabetes
does not fall within the purview of RCW 28A.210.260. Given no statutory or regulatory guidance on
this issue, school districts may want to consider an adaptation to district policy and procedure that
would address student self-administration of additional medication. It is recommended that the RN
be involved in the development of all district policies on medication administration.
Possible considerations:
• Define the circumstance that self-administration would be permitted.
• Approval process for self-administration.
• Developmental/grade level of student.
• Type of medication-prescription versus over the counter.
ASTHMA MEDICATION
Summary of Provisions
RCW 28A.210.370 Students with Asthma states:
• All school districts shall adopt policies regarding asthma rescue procedures for each school
within the district.
• All school districts must require that each public elementary school and secondary school
grant to any student in the school, authorization for the self-administration of medication
to treat that student's asthma or anaphylaxis, if:
o A health care practitioner prescribed the medication for use by the student during
school hours and instructed the student in the correct and responsible use of the
medication.
o The student has demonstrated to the health care practitioner, or the practitioner's
designee, and a professional registered nurse at the school, the skill level necessary
to use the medication and any device that is necessary to administer the medication
as prescribed.
o The health care practitioner formulates a written treatment plan for managing
asthma episodes of the student and for medication use by the student during
school hours. The student's parent/guardian has completed and submitted to the
school any written documentation required by the school, including the treatment
plan.
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• Students must be allowed to self-carry and self-administer their asthma medication:
o While in school.
o While at a school-sponsored activity, such as a sporting event.
o In transit to or from school or school-sponsored activities.
• An authorization for asthma medication.
o Must be effective only for the same school and school year for which it is granted.
o Must be renewed by the parent/guardian each subsequent school year.
• School districts must require that backup medication, if provided by a student's
parent/guardian, be kept at a student's school in a location to which the student has
immediate access in the event of an asthma or anaphylaxis emergency.
• School districts must require that information be kept on file at the student's school in a
location easily accessible in the event of an asthma or anaphylaxis emergency.
Special Considerations
• Students with health conditions may qualify for Section 504 accommodations. This needs to
be considered in the development of the student’s Individualized Health Plan (IHP). Follow
district policy and procedure for this process.
• It is important for a UAP to always follow the student’s IHP including the LHP treatment
orders. If there is ever a question about the appropriate action a UAP should take when
administering medication, he or she should contact the registered nurse immediately for
clarification and guidance, however, for the safety of the student, initial treatment should
never be delayed.
• Students with both asthma and anaphylaxis have complex medication and treatment plans.
The RN is responsible for working with the LHP to create a very clear, integrated emergency
care plan to ensure that both conditions are managed appropriately in the school setting,
i.e., the possible use of epinephrine to treat severe respiratory symptoms.
Summary of NCQAC Advisory Opinion - Asthma
Management in School Settings
• The RN may delegate the administration of a varying dose of inhaled asthma medication
(i.e., 1 – 2 puffs) after clarifying with the LHP the circumstances for which the dose should
be administered. *NOTE: The RN is responsible for providing clear, written instructions to
the UAP regarding administration of a varying dose.
• The UAP who has been trained and is supervised by the registered nurse may verify
readings on the peak flow meter and assist the student to identify emergent and urgent
situations and to follow the instructions on their IHP. The registered nurse may not delegate
nursing assessment or the nursing process (clinical decision making) to an unlicensed
individual.
• The RN may delegate to a UAP the mixing of liquid medications in a nebulizer chamber for
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administration via oral inhalation following training and the provision of ongoing
supervision.
See
Nursing Care Quality Assurance Commission-Request for Advisory Opinion from the American
Lung Association, Asthma Management in School Settings Committee (2000)
For additional resources about the care of asthma and treatment modalities, see AMES Manual-
Asthma Management in Educational Settings.
ANAPHYLAXIS MEDICATION
Summary of Provisions
RCW 28A.210.380—Anaphylaxis—Policy—Guidelines describe the requirements for care provided to
students with life-threatening anaphylaxis.
RCW 28A.210.383—Epinephrine auto injectors.
• School districts and non-public schools may maintain at a school in a designated location a
supply of epinephrine auto injectors based on the number of students enrolled in the
school. The epinephrine prescription must be accompanied by a standing order for the
administration of school supplied, undesignated epinephrine auto injectors.
• When a student has a prescription for an epinephrine auto injector on file, the nurse and/or
designated trained school personnel may utilize the school supply of epinephrine auto
injectors to treat symptoms of anaphylaxis when the student’s medication is not available.
• When a student does not have a prior diagnosis and prescription for an auto injector on file,
only the nurse may utilize the school supply of epinephrine auto injectors to treat
symptoms of anaphylaxis.
RCW 28A.210.370 Students with asthma, provides additional guidelines for students with
anaphylaxis. Anaphylaxis is considered a life-threatening health condition and requires special
considerations.
• All school districts must require that each public elementary school and secondary school
grant to any student in the school authorization for the self-administration of medication to
treat that student's anaphylaxis/asthma, if:
o A LHP prescribed the medication for use by the student during school hours and
instructed the student in the correct and responsible use of the medication;
o The student has demonstrated to the LHP and a professional registered nurse at the
school, the skill level necessary to use the medication and any device that is necessary
to administer the medication as prescribed;
o The LHP formulates a written treatment plan for managing asthma episodes of the
student and for medication use by the student during school hours; and
o The student's parent/guardian has completed and submitted to the school any written
documentation required by the school, including the treatment plan.
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• Students must be allowed to self-carry and self-administer their anaphylaxis/asthma
medication:
o While in school
o While at a school-sponsored activity, such as a sporting event
o In transit to or from school or school-sponsored activities
• An authorization for anaphylaxis/asthma medication:
o Must be effective only for the same school and school year for which it is granted
o Must be renewed by the parent/guardian each subsequent school year
• School districts must require that backup medication, if provided by a student's
parent/guardian, be kept at a student's school in a location to which the student has
immediate access in the event of an asthma or anaphylaxis emergency.
• School districts must require that information be kept on file at the student's school in a
location easily accessible in the event of an asthma or anaphylaxis emergency.
RCW 28A.210.320—Children with life-threatening health conditions: For the attendance of students
with life-threatening health conditions, medication and treatment orders, necessary medication(s)
and nursing care plan(s) must be in place prior to the first day of school. This requirement does not
apply to homeless students under the McKinney-Vento Act. School nurses will need to make
special efforts to ensure that necessary nursing plans, LHP orders, and medications and/or
treatments are in place for homeless students.
Special Considerations
This is taken from Guidelines for Care of Students with Anaphylaxis (OSPI, March 2009).
• Some parent/guardians and/or LHPs have requested first giving an antihistamine for certain
symptoms, then “waiting and watching” (assessing student symptoms for progression of
anaphylaxis) and giving epinephrine if additional certain symptoms occur. Deaths have
occurred in schools because of delays in appropriate treatment. Washington State NCQAC
addresses delegating nursing assessment and/or judgment.
• Recommended practice for treating student anaphylaxis during school or school-sponsored
events:
o Epinephrine is to be given immediately and the EMS (911) system activated if a
student known to have anaphylaxis has an exposure or a suspected exposure to an
allergen.
o If an LHP orders the administration of an antihistamine and/or epinephrine, the RN
may use the School Registered Nurse Delegation Decision Tree (see appendix) to
follow RCW 18.79.260 to determine if a non-licensed staff member may carry out
the IHP.
o Address the unique circumstances for each student while retaining adherence to the
scope of nursing practice.
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• It is the parent/guardian’s responsibility to keep school staff informed of changes in the child’s
condition or changes in LHP orders. Prior to the student attending school, upon returning to
school after an absence related to the diagnosis, and any time there are changes in the
student’s treatment plan, parent/guardian should notify the RN.
• Parent/guardian should provide all medications and supplies. *NOTE: District policy may
address the use of automatic epinephrine injectors vs. the use of a syringe.
• Although the epinephrine auto injector device is designed for self-administration, the student
may be too young or too ill to self-administer the epinephrine. Therefore, it is necessary to
train those school employees who will be monitoring the student in the use of the device.
• Epinephrine auto injectors must be kept between 59- and 86-degrees Fahrenheit. Districts
will need to take this into consideration during temperature extremes, on field trips, etc.
• Students with anaphylaxis may qualify for Section 504 accommodations. This should be
considered in the development of the student’s IHP. Follow district policy and procedure
for this process.
Standing Orders for Stock Epinephrine
A school supply of undesignated epinephrine autoinjectors (stock epinephrine) is an option in
Washington State schools but is not mandated. Any district considering this option must be aware
of the specific actions required by RCW 28A.210.383 Epinephrine auto injectors (Epi pens) – School
supply – Use. The statute addresses the conditions under which districts or schools may stock
undesignated supplies of epinephrine and are addressed in the WSSDA Anaphylaxis Prevention
model Policy #3420 and Procedure #3420P (2018). See the 2021
Guidelines for Care of Students
with Anaphylaxis, SECTION 5, for more information.
The Washington State NCQAC provides the following recommendations in its Advisory Opinion –
Standing Orders and Verbal Orders:
• Schools may allow RNs to follow standing orders, using stock inventory, to give epinephrine
for potentially life-threatening allergic reactions (RCW 28A. 210.383). The law does not allow
delegation to a UAP to give epinephrine without a student-specific prescription.
• Nursing leadership should be involved in developing and approving standing orders.
• School districts may have policies and procedures to implement standing orders and verbal
orders.
• Standing orders should be reviewed and revised as needed, or annually.
• Changes to standing orders should be communicated as soon as possible to nursing staff
and these should be reviewed by nursing staff as changes occur.
PARENT DESIGNATED ADULT (PDA) FOR
DIABETES AND SEIZURES
The school district is ultimately responsible for providing nursing care to students at school and
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school sponsored events. In addition, RCW 28A. 210.260, RCW 28A.210.355, and RCW
28A.210.330 allow parents of students with epilepsy or diabetes to select a “parent designated
adult” to provide parent-directed nursing care in school.
A "parent designated adult" (PDA) means a volunteer who may be a school district employee, who
receives additional training from a health care professional or expert in epileptic seizure or diabetes
care selected by the parent/guardians, who provides care for the child consistent with the
individual health plan.
Per Washington State law, these are the only two situations (diabetes and seizures) that allow a
PDA to administer medication and treatments to students in the school setting. In both cases the
RN does not delegate, train or supervise the PDA in the activities designated by the
parent/guardian. They do, however, work together to follow the student’s IHP.
To be eligible to be a parent designated adult, a school district employee not licensed under
chapter 18.79 RCW shall file, without coercion by the employer, a voluntary written, current, and
unexpired letter of intent stating the employee's willingness to be a parent designated adult. If a
school employee chooses not to file a letter under this section, the employee shall not be subject
to any employer reprisal or disciplinary action for refusing to file a letter.
Registered nurses do not delegate or supervise parent designated tasks, including injections.
Parent/guardians are responsible to determine, direct, and supervise such care. However, the RN is
ultimately responsible for the student’s overall plan of care.
For additional resources see:
• PDF Guidelines for Care of Students with Diabetes OSPI and Washington State Department
of Health. (2018).
• PDF on Curriculum Standards for Developing Curricula to Train Parent Designated Adults
(PDAs) Working with Students with Diabetes (2009).
DIABETES MEDICATION
Summary of Provisions
RCW 28A.210.330-350: Students with diabetes—Individual health plans—Designation of
professional to consult and coordinate with the parents and health care provider - training and
supervision of school district personnel, addresses comprehensive care for students with diabetes
in school. The RN is ultimately accountable for the quality of the healthcare provided during the
school day to students with diabetes. The RN has the responsibility of consulting and coordinating
with the student’s parent/guardian and the LHP to establish a safe, therapeutic learning
environment. Schools are responsible for ensuring that there is an IHP and emergency care plan
(ECP) for every student with diabetes even those who are independent in their care.
• An LHP order is needed for the monitoring and treatment of diabetes at school.
• Students must be allowed to carry on their persons the necessary supplies and equipment
(including medication) to perform diabetic monitoring and treatment at all school and
school-sponsored events.
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• The law also allows for a “parent designated adult” (PDA) to administer medication and
perform diabetic tasks determined by the parent/guardian and consistent with the
individual health plan.
Parent Designated Adult (PDA)
The school district is ultimately responsible for providing nursing care to students at school and
school sponsored events. In addition, RCW 28A.210.330 allows parents of students with diabetes
to select a “parent designated adult” to provide parent-directed nursing care in school.
• A PDA is a volunteer who may be a school district employee who receives additional
training from a healthcare professional or expert in diabetes care, selected by the
parent/guardian and who provides care for the student consistent with the IHP.
• To be eligible to be a PDA, a school district employee, not licensed under RCW 18.79
must
file, without coercion by the employer, a voluntary written, current, unexpired letter of
intent stating the employee’s willingness to be a PDA.
• If the school district employee chooses not to be a PDA, the employee shall not be subject
to any employer reprisal or disciplinary action.
• PDA training may be provided by a diabetes educator who is nationally certified.
• PDAs who are not school employees must show evidence of comparable training.
• The school’s RN is not responsible for the supervision of the PDA for those procedures that
are authorized by the parent/guardian; however, the RN is still responsible for the overall
plan of care.
Special Considerations from Guidelines for the Care of
Students with Diabetes, 2018
• The LHP, parent/guardian, and RN make the decision regarding the student’s ability to
provide diabetic care independently.
• Students who are independent in their own diabetic care also require LHP medication and
treatment orders.
• Adjustments in the daily dosage of insulin can be made in consultation with the
parent/guardian as long as the parent/guardian’s recommendations are within a range
ordered on the LHPs written sliding scale. The LHP must clearly state that the
parent/guardian may be consulted for daily dosage adjustments.
• Parent/guardians may not order treatments or changes to the treatment plan
independently because they are not authorized prescribers.
• The RN, guided by RCW 18.79 and WAC 246-840, determines what diabetes tasks can be
delegated to a UAP.
• After delegation, training, and with ongoing supervision, the UAP can follow the IHP; verify
the number on an insulin pen, insulin pump, or glucometer.
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• The student, parent/guardian/family, licensed staff, and parent designated adult can
perform any tasks related to diabetic care.
• Students with diabetes may qualify for Section 504 accommodations. This needs to be
considered in the development of the student’s IHP. Follow district policy and procedure
for this process.
• Registered nurses may delegate intranasal glucagon but may not delegate the
administration of injectable glucagon to UAPs per RCW 28A.210.260.
SEIZURE MEDICATIONS
Students with seizures may require emergency medications at school for the management of repeated
or prolonged seizures. The student’s LHP will determine if emergency rescue medication is
necessary at school. Students receiving medication for the control of their seizures should have a
written IHP/ECP with instructions for how to manage the student’s seizures during school hours
and school sponsored events.
Summary of Provisions
Requirements for the care of students with seizures are addressed in RCW 28A.210.355 Students
with epilepsy or other seizure disorders.
Effective for the 2022–2023 school year, 28A.210.355 requires school districts to adopt policies
which address:
• Parent requests and instructions.
• Orders from a Licensed Health Care Provider.
• Storage of equipment and medications provided by parents.
• Policy exceptions necessary to accommodate the needs of students with epilepsy or seizure
disorders.
• Development and distribution of an individualized health plan and emergency care plan for
students with epilepsy and seizure disorders, to be updated annually.
• Parent-designated adults: legal documents and training.
This section also allows training for school personnel to be provided by a national epilepsy
organization that offers seizure training and education for school nurses.
RCW 28A.210.260 Public and Private School Administration of Medication addresses:
• The RN may delegate medications for the treatment of seizures via the following routes:
oral, topical, eye drops, ear drops or nasal spray. This law does not allow for the delegation
of rectal medication.
• A nasal spray that is a legend drug or a controlled substance may be administered by a
trained school employee or parent designated adult (PDA) who is not a school nurse.
• The board of directors shall allow school employees, who have received appropriate training
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and volunteered for such training, to administer a nasal spray that is a legend drug or a
controlled substance.
Regardless of who administers an emergency seizure medication, emergency medical assistance
should be summoned except in instances when the administration of the nasal spray occurs
routinely as documented in emergency care plan signed by parent or guardian and LHP.
The board of directors shall designate a professional person, licensed, pursuant to RCW 18.71 or
RCW 18.79 as it applies to registered nurses (RN) and advanced registered nurse practitioners
(ARNP), to delegate to, train, and supervise the designated UAP in proper medication procedures.
PDAs must receive additional training per RCW 28A.210.260.
RCW 28A.210.320 Children with Life-Threatening Health Conditions:
• This law adds a condition of attendance for students with life-threatening conditions.
Treatment and medication orders and nursing care plans requiring medical services must be
in place prior to the first day of school.
Parent Designated Adult (PDA)
The school district is ultimately responsible for providing nursing care to students at school and
school sponsored events. In addition, RCW 28A.210.355 allows parents of students with epilepsy to
select a “parent designated adult” to provide parent-directed nursing care in school.
• PDA is a volunteer who may be a school district employee selected by the parent/guardian,
and who:
o receives additional training from a healthcare professional, expert in epileptic
seizure care, or national organization that offers training for school nurses for
managing students with seizures and seizure training for school personnel,
o who provides care for the student consistent with the IHP.
• To be eligible to be a PDA, a school district employee, not licensed under RCW 18.79 must
file, without coercion by the employer, a voluntary written, current, unexpired letter of
intent stating the employee’s willingness to be a PDA.
• If the school district employee chooses not to be a PDA, the employee shall not be subject
to any employer reprisal or disciplinary action.
• PDA training may be provided by an epilepsy educator who is nationally certified. Required
training may also be provided by a national organization that offers training for school
nurses for managing students with seizures and seizure training for school personnel. PDAs
who are not school employees must show evidence of comparable training.
• The school’s RN is not responsible for the supervision of the PDA for those procedures that
are authorized by the parent/guardian; however, the RN is still responsible for the overall
plan of care.
Special Considerations
• A Vagal Nerve Stimulator is not a medication. It is considered a treatment that is used for
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the management of seizures and can be delegated to UAP by the RN.
• Students with seizures may qualify for Section 504 accommodations. This needs to be
considered in the development of the student’s IHP. Follow district policy and procedure
for this process.
• For additional resources about the care of seizures and treatment modalities, see NCQAC
documents:
o Seizure Disorder Management: Nursing Care Coordination (PDF)
o Registered Nurse Delegation in School Settings: Kindergarten-Twelve (K-12) Grades,
Public and Private Schools
*NOTE: When considering delegation of emergency seizure medication as taken from RCW
18.79.260, “No person may coerce a nurse into compromising patient safety by requiring the
nurse to delegate if the nurse determines that it is inappropriate to do so. Nurses shall not be
subject to any employer reprisal or disciplinary action by the Nursing Care Quality Assurance
Commission for refusing to delegate tasks or refusing to provide the required training for
delegation if the nurse determines delegations may compromise patient safety.“
ADDITIONAL GUIDELINES
Medication versus Non-Medication
Parents/guardians sometimes request that school staff administer alternative or non-traditional
substances to their child while at school or school sponsored events. Questions may arise as to
whether a given substance constitutes a medication.
According to Webster’s 3rd New International Dictionary, “a medication is a substance used in
therapy or to cure disease or relieve pain”. Not all substances are medications. Vitamins, for
example could be used to cure disease or relieve pain, or they might be used as simply a nutritional
supplement. They could be considered a medication if taken for the former purpose but not the
latter.
According to Federal Drug Administration (FDA), the term “drug” means articles recognized in the
official United States Pharmacopoeia, official Homeopathic Pharmacopoeia of the United States, or
official National Formulary, or any supplement to any of them; and articles intended for use in the
diagnosis, cure, mitigation, treatment, or prevention of disease in man or other animals.
Schools lack the necessary expertise to determine the purpose for which a particular substance is
taken. Fortunately, the law requiring a written LHPs request appears to shift the responsibility for
making the determination to the LHP. If the substance is considered a medication by the LHP, there
will need to be a LHP and parent/guardian request per RCW 28A.210.260.
The administration of any medication must follow all applicable statutes, regulations, standards of
practice, and district policies and procedures. District policies and procedures should address the
administration of non-traditional substances, as some are experimental, unlabeled, administered at
doses in excess of manufacturer guidelines, or not approved by the FDA for safety or effectiveness.
The RN should refer to the School Registered Nurse Delegation Decision Tree (see appendix) to
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determine whether delegation of an alternative or non-traditional substance is appropriate.
Examples of some alternative and non-traditional substances are provided below.
• Vitamins/Supplements
• Herbal or Homeopathic preparations
• FDA non-approved drugs
• Sunscreen
• Lip balm
• Cough drops
• Enzymes
• Probiotics
• Nicorette Gum
• Petroleum jelly
• Chloraseptic spray
• Caffeine
• Sting relief
• Eye wash
• Placebo and research meds
• Essential oils
• Aromatherapy
For additional resources:
Food and Drug Administration - Complementary and Alternative Medicine Products and their
Regulation
Food and Drug Administration - Is it a Cosmetic, a Drug or Both?
Oxygen
Oxygen is sometimes ordered by an LHP for students with respiratory conditions. In RCW
18.64.011, the definition excludes oxygen as a medication, however, a LHP order/prescription is
required for it to be administered at school.
It is the responsibility of the RN to determine if delegation of oxygen to UAP is appropriate based on a
nursing assessment, LHP orders, and stability of the student’s health condition. To help in the decision,
the RN may use the NCQAC’s School Registered Nurse Delegation Decision Tree (see appendix).
The LHP may prescribe a varying dose of oxygen flow rate (liters per minute). RNs may delegate
the administration of a varying dose after clarifying with the LHP the circumstances for which dose
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should be administered. *NOTE: The RN is responsible for providing clear, written instructions to
the UAP regarding administration of a varying dose of oxygen.
The use and storage of oxygen in schools requires careful training, preparation and planning by the
RN prior to implementation.
Medical Marijuana (Cannabis)
RCW 28A.210.325: Medical use of marijuana-infused products allows parents to administer
medically authorized marijuana-infused products to their child in the school setting within certain
parameters. School districts must permit students who meet the requirements of RCW 69.51.A.220
to consume marijuana-infused products for medical purposes on schools grounds, aboard a school
bus, or while attending a school-sponsored event. The Board of Directors shall adopt a policy to
authorize parents or guardians to administer marijuana-infused products for medical purposes
upon request of a parent or guardian. Policy must, at minimum, include:
• Authorization of administration by a parent or guardian to a student for medical purposes
pursuant to RCW 69.51A.220.
• Establish protocols for verifying the student is authorized to use marijuana for medical
purposes.
• Expressly authorize parents or guardians who have been authorized to use marijuana for
medical purposes to administer marijuana-infused products to the student while the
student is on school grounds.
• Identify locations on school grounds where marijuana-infused products may be
administered.
• Prohibit the administration of medical marijuana to a student by smoking or other methods
involving inhalation while the student is on school grounds, aboard a school bus, or
attending a school-sponsored event.
• While this law is permissive, marijuana remains a Schedule I (illegal) substance under federal
law, potentially jeopardizing federal funding for agencies or school districts that
accommodate it.
The Nursing Care Quality Assurance Commission Advisory Opinion (NCAO 17) Administration of
Cannabis/Marijuana Products in School Settings: Kindergarten-Twelve (K-12) Grades, Public and
Private Schools states that administration and delegation of marijuana-infused products are not
within the scope of RN or LPN practice. It is within the RN and LPN scope of practice to administer
FDA approved prescription cannabis/marijuana derived products in schools. Only parents or
guardians are authorized to administer marijuana-infused products.
Per the
Administration of Cannabis/Marijuana Products in School Settings: Kindergarten-Twelve (K-
12) Grades, Public and Private Schools Advisory Opinion:
“The commission determines:
• It is not within the nursing scope of practice to administer or delegate to assistive personnel
to administer or give authorized medical marijuana/cannabis products or marijuana-infused
products.
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• It is not within the nursing scope of practice to provide storage and handling of authorized
medical marijuana/cannabis products or marijuana-infused products.
• It is not within the scope of practice of a nurse or of assistive personnel to act as a parent
designated adult to administer authorized medical marijuana/cannabis products or
marijuana-infused products.
• The laws and rules do not prohibit a nurse from validating medical marijuana
authorizations.
• The nurse must communicate changes in a student’s condition to members of the health
care team.
• The nurse must document assessments, observations, care given, and response to care. The
commission recommends keeping a record of when parents give authorized medical
marijuana-infused products to their child.
• It is expected the nurse will give emergency care and first aid as necessary.”
Additional resources regarding marijuana in schools:
• OSPI Bulletin NO. 052-19 Medical Marijuana Administration to Students
• Minor patient access to medicinal marijuana within a school setting INFORMATION FOR
PUBLIC SCHOOL OFFICIALS – Valid Recognition (Attachment 1 to BO52-19)
• Washington State Department of Health Website: Medical and Recreational Marijuana
Opioid-Related Overdose Reversal Medication
Per RCW 28A.210.390, for the purpose of assisting a person at risk of experiencing an opioid-
related overdose, a high school may obtain and maintain opioid overdose reversal medication
through a standing order prescribed and dispensed in accordance with RCW 69.41.095.
This law requires school districts with 2000 students or more to obtain and maintain at least one
set of opioid overdose reversal medication doses in each of its high schools effective in the 2020–
21 school year. A statewide standing order for naloxone that “shall be considered a naloxone
prescription for an eligible person or entity. This standing order authorizes any eligible person or
entity in the state of Washington to possess, store, deliver, distribute or administer naloxone.”
RCW 28A.210.395 required the Office of the Superintendent of Public Instruction to develop
opioid-related overdose policy guidelines and training requirements for public schools and school
districts. The guidelines must include information about:
• The identification of opioid-related overdose symptoms.
• How to obtain and maintain opioid overdose reversal medication on school property issued
through a standing order.
• How to obtain opioid overdose reversal medication through donation sources.
• The distribution and administration of opioid overdose reversal medication by designated
trained school personnel.
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• Free online training resources that meet the training requirements in this section.
• Sample standing orders for opioid overdose reversal medication.
The Nursing Care Quality Assurance
Commission Advisory Opinion NCAO 8.10 Prevention and
Treatment of Opioid-Related Overdoses states:
“The RCW 28A.210.260 allows the school RN to delegate administration of an intranasal opioid
antagonist if the school RN is not on the premises. The law does not allow delegation to UAP in
schools of opioid antagonists by injection. UAP may administer an intranasal or injectable opioid
antagonist prescribed to a student without delegation or administer intranasal or injectable opioid
antagonist as a bystander. RCW 28A.210.390 requires Class I high schools with more than 2,000
students to have stock Naloxone and designated staff to administer the drug. RCW 28A.210.390
and RCW 28A.210.395 define the requirements for schools related to the prevention of opioid
overdoses.”
Resources:
• Model policy and Procedure
from the Washington State School Directors Association
• Naloxone Instructions: Washington State Department of Health
• Stopoverdose.org | Helping individuals and communities in Washington State respond to
prevent opioid overdose.
Medication Orders for Students of Military Families
The Interstate Compact on Educational Opportunity for Military Children, RCW 28A.705, aims to
provide consistency as much as possible with other states relative to school policies and
procedures while honoring the existing laws that govern public education in our state. Medication
orders should not be a barrier to timely enrollment of children of military families. RCW 69.41.030
allows orders to be accepted from qualified prescribers from any state within the United States.
For additional information about qualified prescribers see
Who Can Prescribe and Administer
Prescriptions from Washington State Department of Health.
Medication Orders for Students Experiencing
Homelessness
The McKinney-Vento Act requires schools to enroll homeless children and youth immediately, even
if they lack the normally required documents. The federal McKinney-Vento Act supersedes
Washington State law RCW 28A.210.320 Children with Life-Threatening Health Conditions.
There is no exception in the McKinney-Vento Act for students with medical conditions; a district
cannot delay enrollment.
The McKinney-Vento Act requires that unaccompanied youth be enrolled in school immediately,
even without a parent/guardian. The RN should work with the district McKinney-Vento Act liaison
to ensure that the student’s health care needs are addressed as soon as possible.
For additional information contact your district McKinney-Vento liaison and/or the OSPI Homeless
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Education Office at (360) 725-6050 or see Homeless Education at OSPI.
FIELD TRIPS, SCHOOL SPONSORED EVENTS
AND SUMMER SCHOOL
Standards for safe medication administration do not change when students participate in field
trips, school sponsored events, or summer school. This includes appropriate training, delegation,
and supervision of the UAP by a RN. The goal of school districts should be to facilitate all students’
participation in all school activities. It is especially important to plan ahead for any student with a
chronic or life-threatening health condition who may participate in an overnight field trip. The
student may need medication that they normally takes only at home. All of the requirements of the
medication statutes RCW 28A.210.260 and RCW 28A.210.270 and school district policies and
procedures must be met.
If a student requires medication to be administered during a field trip, school sponsored event or
summer school, procedures must be in place to assure safe administration: The student must have
a completed medication authorization form on file with the LHP and parent/guardian signature. A
copy of the form should accompany the student on any field trip.
• Ensure the student’s medication authorization form includes dates for summer school when
applicable.
• For field trips or school sponsored events that extend beyond regular school hours, the
parent/guardian is responsible to obtain a medication authorization form with specific
instructions for the extended hours. If the medication is to be administered during the
regular school day, the current medication authorization form on file should be followed.
• RNs cannot delegate medication administration to volunteers, parent/guardians, or non-
school employees during school or during school sponsored events. This includes licensed
nurses who are not district employees.
• Parent/guardians who accompany children to any school sponsored event may administer
medication to their own child but not to any other children.
• UAP who will be administering medications must be trained, delegated to, and supervised
in medication administration by the RN.
• RN or designee should prepare field trip packet including medications, medication
authorization forms, medication administration record (med log), and IHPs when applicable,
and give them to the delegated UAP who will be administering the medications.
• The medication to be administered by the UAP must be kept in the original container with
the student’s name on the container and carried in a fanny pack or locked box with limited
but immediate access for emergency medications.
• Medication that needs to be refrigerated must be kept in a small cooler with ice packs if a
refrigerator is not available. *NOTE: Be aware of temperature extremes that may affect
medications. For example, epinephrine auto-injectors must be kept between 59- and 86-
degrees Fahrenheit and so it is inadvisable to store them in a locked box in a car trunk or on
a bus during hot weather without a cooling pack.
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• Documentation should be completed on the student medication administration record as
soon as the medication is administered per district policy and procedure.
• If a student is capable of self-administration per school district policy and procedure, a plan
of action should be developed by the RN to assist in meeting the needs of the student.
• If the student does not already self-administer medication at school, the student will require
training and support by parent/guardian and the RN before assuming this responsibility on a
field trip, school sponsored event, or summer school. This student may require additional
adult supervision to ensure their safety.
• Upon return from a field trip, any unused medication must be returned to the RN or
designee and documentation completed in accordance with the school district’s procedure.
• The RN or designee and the UAP should sign and date a log sheet that documents the
return of the medication and any problems that might have occurred with the medication
administration on the field trip such as a dropped medication, missed dose, or student
refusal.
Section 504 may apply to the administration of medication to a student with a qualifying disability,
including their participation in field trips, school sponsored events, and summer school. If the student
is receiving health services during regular school hours, then the district must provide health
services for the student on field trips, school sponsored events, and summer school. Appropriate
accommodations may include:
• Assigning a licensed nurse to provide care for the student.
• RN delegation of care to a UAP, following appropriate delegation procedures.
• Though they cannot be required to do so, parents/guardians may be asked to accompany the
student and attend to the student’s health care needs.
• If neither of these options are possible or the student should not go on the field trip or school
sponsored event because of the unstable/fragile nature of their condition and/or the distance
from the emergency care that might be required, the school may provide a comparable
learning experience at school or in an alternate, safe location.
See also: Parent and Educator Resource Guide to Section 504 in Public Elementary and Secondary
Schools
For additional information regarding Section 504 contact:
Your district 504 officer or team
OSPI Office of Equity and Civil Rights (360) 725-6162 or Equity and Civil Rights at OSPI.
OSPI Health Services (360) 725-6040 or Section 504 website: Section 504 & Students with
Disabilities at OSPI.
Field Trips Out of State and Out of Country
School districts should have policies and procedures for out of state and country trips. If these do
not exist, the school RN should work with district administration and legal counsel to address how
the medication/treatment needs of students will be addressed. Washington State is not a member
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of a nursing licensure compact. Therefore, a Washington State registered, or licensed practical
nursing license is not valid in other states or countries. The nurse must contact the boards of
nursing in the appropriate state for guidance and permission to practice (including delegation to
school staff) in that state or determine if the state grants visiting privileges. The nurse may be
required to obtain licensure in another state to be able to administer medication/treatments to
students or to be able to delegate administration of medication/treatments to school staff if
delegation is permissible in that state. For trips outside the country, the school nurse must contact
the visiting country for guidance and permission. It is best to get guidance in writing and have
these documents readily available.
DISASTER PLANNING
When districts plan for potential disaster situations, student medication needs must be addressed.
Safety is the goal. Considerations should include, but are not limited to:
• Development of disaster preparedness plans to accommodate a minimum of 72 hours
without access to care.
• Having at least a three-day supply of medications on hand for students who take medications
during the school day.
• The RN or designee contacts parent/guardian to identify medications that students take only at
home and to whom the missing of three days of medications could pose a serious health risk
for the student or others. The parent/guardian should be asked to provide a three-day supply
of these medications and the necessary parent/guardian and LHP requests and instructions. In
some instances, by working with the student’s LHP and parent/guardian, the need for the
medication can be attenuated or delayed. For instance, insulin dosage may be altered based
on food intake and activity level to require less insulin. Some medications may have a longer
half-life permitting students to miss a number of doses without serious consequences. These
situations must be clarified by the RN to ensure that those students needing medication receive
the amount they need in situations where medications cannot be readily obtained without
prior planning.
• Ha
ving medications securely and properly stored according to prescription container
directions, e.g., refrigerated and monitored for expiration dates. It may be necessary to
periodically rotate the school’s disaster medications for an individual student to ensure there are
no expired medications at school.
• Ensuring each student’s IHP contains specific, detailed instructions and diagrams which
could be easily understood by UAPs who could assist the student if a nurse was unavailable
during a disaster.
Additional resources
• Guidelines for the Care of Students with Diabetes
• 2018 Guidelines for Care of Students with Anaphylaxis (2009)
Page | 46
FREQUENTLY ASKED QUESTIONS
1. Can a district accept and/or administer an expired medication? No, in 1979, the
U.S. Food and Drug Administration (FDA) began requiring an expiration date on
prescription and over-the counter medicines. The expiration date is a critical part of
deciding if the product is safe to use and will work as intended. Therefore, schools
should not accept medications that are expired unless there has been a notification
from the FDA with an exception for that medication at that time.
2. How do you correctly dispose of expired medication in a school setting? Refer to
your district’s policy/procedure or guidelines for medication disposal. Regulations vary
by county. Consult your facilities department, local pharmacy, or waste management.
There are often local community programs that will “take back” some medications. See
also, State and Federal guidance below:
a. Disposal of Unused Medicines: What You Should Know
(US F.D.A)
b. How to Dispose of Unused Medicines (US F.D.A)
c. Take Back Your Meds (takebackyourmeds.org)
d. What You Can and Cannot Take Back (US F.D.A)
e. DOH Safe Medication Return Program (Washington State DOH)
f. How to Dispose of Medicines Properly (E.P.A.)
3. Can a school RN or LPN accept a Licensed Healthcare Provider’s (LHP) verbal
telephone order? Yes, it is within the scope of practice of a licensed nurse to take a
verbal/phone/fax order from the LHP. The verbal order must be followed by the written
order in a reasonable period of time. Refer to the
Nursing Care Quality Assurance
Commission Standing Orders and Verbal Orders Advisory Opinion, 2014) for further
guidance.
4. What process does a district follow if there has been a medication theft? Theft or
suspected theft is to be documented and reported to the supervising nurse and
building administrator. Theft or suspected theft may also be reportable to local law
enforcement.
5. Can medications be mixed with food such as applesauce or pudding for students
who have difficulty swallowing? Yes, only if you are not altering the form or dose by
doing so. Cutting, crushing, or sprinkling of the medication are examples of altering the
form of an oral medication. If the form of a medication must be changed, the
prescribing LHP should indicate this on the medication authorization form and
pharmacy label. The following resource may be helpful in providing additional
guidance:
Oral Dosage Forms That Should Not Be Crushed from the Institute For Safe
Medication Practices (ismp.org)
6. Can the school registered nurse delegate the reading of numbers on an insulin
pump? Yes, with training, delegation, and supervision from the school nurse, UAPs may
verify the number shown on the screen of the insulin pump but, non-licensed school
personnel, other than one who is a PDA, may not assist with the pump settings.
Guidelines for the Care of Students with Diabetes
2018
7. Can a school RN delegate naturopathic medications or remedies? Yes, the Nurse
Practice Act requires nurses to execute the medical regimen as prescribed by health
professionals. Naturopathic physicians are listed as a health professional that that may
direct nursing care. The registered nurse may delegate tasks of nursing care to other
Page | 47
individuals when the registered nurse determines that it is in the best interest of the
patient. Who Can Prescribe and Administer Prescriptions in Washington State
– DOH
8. Is a Vagal Nerve Stimulator (VNS) considered a treatment and can the school RN
delegate? Yes, VNS is a treatment. UAPs may, as delegated by the RN, activate devices
such as vagal nerve stimulators, if their use is part of the IHP for the care and safety of
the student. NCQAC Registered Nurses Coordinating Seizure Management 2005
9. Who can administer glucagon to a student in a school setting? A licensed nurse
(RN, ARNP or LPN), PDA, or parent/guardian/family may administer injectable
glucagon. The administration of injectable Glucagon cannot be delegated to
unlicensed school staff. Intranasal glucagon, a nasal spray, may be delegated to
unlicensed school staff. Guidelines for the Care of Students with Diabetes
10. Can a school district accept a LHP order for the administration of medical
marijuana (cannabis) in school? No. The Nursing Care Quality Assurance Commission
Advisory Opinion (NCAO 17)
Administration of Cannabis/Marijuana Products in School
Settings: Kindergarten-Twelve (K-12) Grades, Public and Private Schools states that
administration and delegation of marijuana-infused products are not within the scope
of RN or LPN practice. It is within the RN and LPN scope of practice to administer FDA
approved prescription cannabis/marijuana derived products in schools. Only parents or
guardians are authorized to administer marijuana-infused products. See section on
Medical Marijuana, p. 34.
11. A
re patches considered topical medication? Yes. Patches are adhesive backed
systems that provide a continuous release of medication through the skin. RCW 28A.
210.260
12. Can schools in WA State use stock medications other than epinephrine? The only
legal references to the use of stock medications in Washington State schools is for
epinephrine auto-injectors RCW 28A.210.383 and Naloxone RCW 69.41.095, RCW
28A.210.390 and RCW 28A.210.395
13. How long does a district need to keep medication administration records?
Medication Administration daily logs and error report forms: retain for 8 years.
Medication Inventory: Retain for 1 year after medications returned, destroyed, or
delivered to law enforcement agency then destroy.
Public Schools (K-12) Records
Retention Schedule
14. Can the school registered nurse give out “RID” head lice shampoo to families for
the treatment of head lice? No, this could be considered diagnosing and dispensing
medication which would constitute unlawful practice of medicine. (Attorney General
Memorandum Dispensing “RID” for Head Lice – 1984; available upon request)
15. Can medications be administered intravenously at school? And by whom? Yes, but
this task is exclusively a licensed practitioner function, and the activity must be within
the provider’s individual scope of practice (training, knowledge, skill and ability to
perform the activity competently) RCW 18.79.
16. Can the registered nurse in a school setting delegate mixing liquid medications
via a nebulizer chamber for administration via oral inhalation? Yes, if the
registered nurse has trained, delegated to, and is supervising the UAP to place
medication in a nebulizer chamber, and if he/she has determined this is a safe
procedure within an individual plan of care.
Nursing Care Quality Assurance
Page | 48
Commission-Request for Advisory Opinion from the American Lung Association, Asthma
Management in School Settings Committee (2000)
17. May the registered nurse in a school setting delegate to unlicensed staff the
administration of inhaled medication with a medication authorization that
provides a varying dose of medication (i.e., one to two puffs)? Yes, if such orders
are clarified with the authorized prescriber by the registered nurse, this type of
medication may be delegated. The registered nurse should contact the authorized
provider to determine, for instance, under which circumstances one versus two puffs of
an asthma medication should be administered. Nursing Care Quality Assurance
Commission-Request for Advisory Opinion from the American Lung Association, Asthma
Management in School Settings Committee (2000)
18. Is sunscreen considered a medication? Sunscreen is categorized as a medication
because it is regulated by the Food and Drug Administration. However RCW
28A.210.260 specifically excludes topical sunscreen products from the medication
statute. Per RCW 28A.210.278, Topical sunscreen products—Sun safety guidelines allows
students, parents, and school personnel to possess and apply topical sunscreen products
while on school property, at school related events or activities or at summer camps
without a prescription or note from a licensed health care professional if the product is
regulated by the US Food and Drug Administration (FDA) for over-the-counter use.
Sunscreen must be supplied by parents or guardians for student use. School employees
are not required to assist students in application of sunscreen products.
19. When should medication be counted? Medication should be counted upon the
school’s initial receipt of and periodically as noted in the district’s medication policy and
procedure; Controlled substances should be counted weekly as recommended by the
Board of Pharmacy. Medication should be counted when discontinued, expired, at the
end of the school year, or any time the medication is picked up by the parent/guardian.
20. If a student appears to be having an allergic reaction, but I am uncertain if the
student was truly exposed to any food containing the allergen, what should I do?
Follow the student’s IHP. If ordered, treat the student immediately with epinephrine, call
911, and follow the IHP. When in doubt, treat the student. Students may have a delayed
reaction. Fatalities occur because the epinephrine was administered too late.
21. Can my child’s epinephrine be stored in the classroom? Yes. Students are entitled to
have backup medication in a location to which the student has immediate access. The
classroom may very well be an appropriate location to store epinephrine. RCW
28A.210.370
22. Can a school RN accept an electronic/digital LHP signature for a medication
order? Yes, although there is nothing in the law or rule that explicitly mentions
electronic health care orders, it is common practice to consider them valid orders. The
electronic system used should have the required authentication information. If there
are questions regarding the validity, the RN should authenticate by making a call to the
provider just as if it were a paper order.
a. EHR: Authentication of Entries, Audio Seminar/Webinar (2007)
b. PDF Signature Guidelines for Home Health & Hospice Medical Review
c. Is the Electronic Signature a Good Idea or a Bad Idea? (chron.com)
23. Does a student with a “life-threatening health condition”, as defined by state law,
automatically qualify as a disabled student under Section 504 for the purposes of
Page | 49
FAPE? Yes. RCW 28A.210.320 defines “life-threatening health condition” as a health
condition that puts a student in danger of death during the school day if a medication
or treatment order and a nursing care plan are not in place. By definition, a student
with a “life-threatening health condition” has a physical or mental impairment that
substantially limits a major life activity and qualifies as a disabled student under
Section 504 for purposes of FAPE. Parent and Educator Resource Guide to Section 504
in Public Elementary and Secondary Schools
24. Is the school district responsible for medication management for students
participating in an outside agency educational or childcare program that is
housed on school property, before, during or after the school day? This is a
complex and challenging question and there is not a clear answer. School
administrators should discuss the specific situation with district legal counsel to
determine district responsibilities.
25. Can a licensed nurse (RN & LPN) practicing in a school setting respond to a
student opioid overdose by administering an opioid antagonist (i.e., Naloxone)?
Yes, the following personnel may distribute or administer the school-owned opioid
overdose reversal medication to respond to symptoms of an opioid-related overdose
pursuant to a prescription or a standing order issued in accordance with
RCW 69.41.095: (i) A school nurse; (ii) a health care professional or trained staff person
located at a health care clinic on public school property or under contract with the
school district; or (iii) designated trained school personnel.
26. How do I know if a medication can be delegated in school? Delegation is limited to
specific routes of administration: topical medications, oral medications, eye drops, ear
drops, and nasal spray medications, with a prescription from an authorized health care
practitioner. With the exception of epinephrine autoinjectors and opioid overdose
reversal medications, piercing of the skin cannot be delegated. There is no list of
approved medications for delegation. See section IV REGISTERED NURSE DELEGATION
IN THE SCHOOL SETTING for a description and principles of the delegation process.
Page | 50
REFERENCES
RCW/WAC
RCW 28A.210.275 Administration of medications by employees not licensed under chapter 18.79
RCW — Requirements — Immunity from liability.
WAC 246-12 Administrative procedures and requirements for credentialed healthcare providers
WAC 246-840-300 Advanced registered nurse practitioner (ARNP) scope of practice
RCW 28A.210.380 Anaphylaxis — Policy guidelines — Procedures — Reports
WAC 246-836-210 Authority to use, prescribe, dispense and order
RCW 18.79 NURSING CARE
RCW 28A.210.320 Children with life-threatening health conditions – Medications or treatment
orders – Rules
RCW 18.64.011(11) Definitions. (11) "Drug" and "devices" do not include surgical or dental
instruments or laboratory materials, gas and oxygen........
RCW 69.50.101 Definitions (Regarding controlled substances)
RCW 70.02.050 Disclosure without patient's authorization — Need-to-know basis
RCW 28A.210.383 Epinephrine auto injectors (EPI pens) — School supply — Use.
WAC 246-840-705 Functions of a registered nurse and a licensed practical nurse
RCW 4.24.300 Immunity from liability for certain types of medical care (Good Samaritan Law)
RCW 69.41 Legend drugs – prescription drugs
RCW 18.79.030 Licenses required — Titles.
RCW 70.02.030 Patient Authorization of disclosure (Laws relating to confidentiality)
WAC 246-840 Practical and Registered Nursing
RCW 28A.210.255 Provision of health services in public and private schools — Employee job
description.
RCW 28A.210.260 Public and private schools — Administration of medication — Conditions.
RCW 28A.210.270 Public and private schools — Administration of medication — Immunity from
liability — Discontinuance, procedure.
WAC 392-380 Public school pupils-immunization requirement and life-threatening health
conditions
RCW 18.79.260 Registered nurse – Activities allowed – Delegation of tasks
Page | 51
RCW 18.130
Regulation of Health Professions – Uniform Disciplinary Act
WAC 392-172-A-01155(1) Related Services (Provision of school health and nursing services related
to special education)
RCW 69.41.030 Sale, delivery, or possession of legend drugs without prescription or order
prohibited- Exception – Penalties
WAC 392-380-045 School attendance conditioned upon presentation of proofs
RCW 28A.210.370 Students with asthma
RCW 28A.210.330-350 Students with diabetes — Individual health plans — Designation of
professional to consult and coordinate with parent and health care provider — Training and
supervision of school district personnel.
WAC 181-87-070 Unauthorized professional practice.
Websites
Camp Nursing (2011) WA State NCQAC Advisory Opinion NCAO 2.0
Curriculum Standards for Developing Curricula to Train PDA’s Working with Students with Diabetes
(June 2009) StandardsforTrainingPDAs (www.k12.wa.us)
Field Trips and Medication Administration (April 1980) WA State NCQAC
Guidelines for Care of Students with Anaphylaxis (March 2009) Allergies and Anaphylaxis | OSPI
(www.k12.wa.us)
Guidelines for Care of Students with Diabetes (May 2005) Diabetes Manual (www.k12.wa.us)
Guidelines for Implementation of School Employee Training on HIV/AIDS and other Blood borne
Pathogens OSPI (April 2011)
Intravenous Therapy by Licensed Practical Nurses Interpretive Statement WA State NCQAC
Registered Nurses (RN) Coordinating Seizure Management Interpretive Statement WA State
NCQAC
Registered Nurse Delegation in School Settings (July 2019) Registered Nurse Delegation in School
Settings: Kindergarten-Twelve (K-12) Grades, Public and Private Schools (wa.gov)
Registered Nurse Delegation in School Settings 4.0 (2014) Archived
Staff Model for the Delivery of School Health Services (April 2001)
Microsoft Word - Title Page-
OSPI.DOC (www.k12.wa.us)
Standing Orders and Verbal Orders (September 2014) WA State NCQAC Advisory Opinion NCAO 6.0
Washington State School Staff Health Training Guide (January 2015) See Medication
Administration, page 12 Staff Health Training Guide (www.k12.wa.us)
Who Can Prescribe and Administer Prescriptions in Washington State? (August, 2014)
Page | 52
Section 504 & Students with Disabilities Section 504 & Students with Disabilities | OSPI
(www.k12.wa.us)
Homeless Education – Resources for Educators OSPI Homeless Education and Resources
Interstate Compact on Educational Opportunities for Military Children (December 2008) Interstate
Compact for Military Children | OSPI (www.k12.wa.us)
OSPI Equity and Civil Rights website and contact information for 504 guidance Equity and Civil
Rights | OSPI (www.k12.wa.us)
Special Education – Laws and Regulations OSPI Website - Special Education
Staff Model for the Delivery of School Health Services (April 2001) OSPI Staff Model for Delivery of
School Health Services
Americans with Disabilities Act 1990 United States Department of Labor ADA
Disposal of Unused Medicines: What you Should Know (February 2015) US Food & Drug
Administration
Individuals with Disabilities Education Act of 1976 US Department of Education IDEA
Take Back your Meds Washington State Coalition of 270 Organizations
The Family Educational Rights and Privacy Act (FERPA) 20 U.S.C. § 1232g; 34 CFR Part 99
Washington State Records Retention Schedule for School Districts and ESDs (Updated June 2020,
see pp. 73-75 for health services) Records Retention Schedule
Page | 53
APPENDICES
This section includes a variety of Sample Forms to assist in the implementation of your district’s
medication management system. You may choose to revise forms to meet the specific needs of
your district and/or community. If you have questions about the content of any form, consult with
your district’s legal advisor.
Links to Sample Forms
• Administering Medication per Gastrostomy Button Bolus Method
• Authorization for Administration of Oxygen
• Discontinuation of Medication Administration at School
• Field Trip Medication Administration Skills Checklist
• Field Trip Medication Record
• Medical Authorization for Asthma Management at School
• Medication Administration Delegation
• Prescription for School Supplied Stock Epinephrine Auto-Injectors for School Use
Pursuant to RCW 8A.210.383
• Sample Medication Administration Early Administration (English and Spanish)
• Sample Medication Administration Incident Report
• Sample Medication Administration Record
• Sample Medication Administration Record with Receipt and Count Logs
• Sample Medication Inventory Record
• Sample Parent Letter Leftover Medication
• Sample Permission to Administer Medication at School
• Sample Receipt for Medication
• Sample Student Skills Checklist for Self-Administration of Emergency Medication
• Sample Authorization to Administer Medication at School
• Severe Allergy Reaction 504 Plan & Medication Orders
• Standing Order for the Administration of School Supplied Stock Epinephrine Auto
Injectors
• Student Agreement to Self-Carry Self Administer Medication
Page | 54
• Topical Ointment Past Salve Cream Skills Checklist
• Transdermal Patch Skills Checklist
• Skills checklist for Intranasal Midazolam Administration
• Sample Spanish/English Discontinuing of Medication Administration
• Sample Emergency Medication Administration Record
• Rescinding Delegation RN
• Sample Oral (Solid) Medication Administration Skill Checklist
• Sample (Liquid) Medication Administration Skills Checklist
• Sample Nasal Spray Skills Checklist
• Sample Metered Dose Inhalers (MDI) Skills Checklist
• Sample Medication Supervision Documentation
• Sample Medication by Nebulizer Skills Checklist
• Medication Received Return Sign In Out Sample Sheet
• Medical Authorization for Asthma Management at School
• General Medication Administration Skills Checklist
• Eye Drops or Ointment Skills Checklist (Sample)
• EpiPen Skills Checklist Procedure
• Ear Drops Skills Checklist (Sample)
• Confidentiality of Student Health Information
Sample Procedures and Policies
• Sample Medication Policies and Procedures WSSDA 3416
• Procedure Medication at School Policy 3416P WSSDA
• Sample Policy for Medication
Page | 55
LEGAL NOTICE
Alternate material licenses with different levels of user permission are clearly indicated next to the
specific content in the materials.
This resource may contain links to websites operated by third parties. These links are provided for
your convenience only and do not constitute or imply any endorsement or monitoring by OSPI.
If this work is adapted, note the substantive changes and re-title, removing any Washington Office of
Superintendent of Public Instruction logos. Provide the following attribution:
“This resource was adapted from original materials provided by the Office of Superintendent of Public
Instruction. Original materials may be accessed at Health Services Resources | OSPI (www.k12.wa.us)
OSPI provides equal access to all programs and services without discrimination based on sex, race,
creed, religion, color, national origin, age, honorably discharged veteran or military status, sexual
orientation including gender expression or identity, the presence of any sensory, mental, or physical
disability, or the use of a trained dog guide or service animal by a person with a disability. Questions
and complaints of alleged discrimination should be directed to the Equity and Civil Rights Director at
360-725-6162 or P.O. Box 47200 Olympia, WA 98504-7200.
Download this material in PDF at Health Services Resources | OSPI (www.k12.wa.us)
. This material is
available in alternative format upon request. Contact the Resource Center at 888-595-3276, TTY 360-
664-3631. Please refer to this document number for quicker service: 22-0020.
Except where otherwise noted, this work by the Washington Office of Superintendent
of Public Instruction is licensed under a Creative Commons Attribution License. All
logos and trademarks are property of their respective owners. Sections used under
fair use doctrine (17 U.S.C. § 107) are marked.
Page | 56
Chris Reykdal | State Superintendent
Office of Superintendent of Public Instruction
Old Capitol Building | P.O. Box 47200
All students prepared for post-secondary pathways,
careers, and civic engagement.
