This fall, Connecticut revised the regulations implementing those provisions of Section 10-212a of the General Statutes concerning administration of medications in school by school personnel. The revised regulations require school districts to develop and implement policies and procedures dictating which school personnel authorized by the statutes will have actual authority in the district to administer medication to students, including so-called “cartridge injectors” to students with severe allergic conditions, and any procedures needed before, during, and after administration of medication. Policies need to be developed in conjunction with the school nursing supervisor and school medical advisor, and will need to be revisited at least once every two years.
In addition, the new rules states that no medication may be administered without the written order of an authorized prescriber, the written authorization of the student’s parent or guardian, AND the written permission of the parent for the exchange of information between the prescriber and the school nurse necessary to ensure the safe administration of the medication. 10-212a-2(b).
Qualified personnel who may be authorized to administer medications to students in school may include coaches and licensed athletic trainers during athletic events and paraprofessionals. 10-212a-2(d)(4) and (5). Investigational drugs or research or study medications may not be administered by school personnel. 10-212a(d)(3). Annual training must be provided to all personnel who will be administering medications, and training must be provided by the school nurse or school medical advisor. 10-212a-3. Schools must keep careful records of the student-specific training that is provided. 10-212a-3(c). Licensed practical nurses (LPN’s) may administer medications under a medication plan established by the school nurse, and if they can demonstrate appropriate training as part of their nursing program. 10-212a-3(d).
The new regulations also require school districts to permit students to self-administer prescribed emergency medications such as asthma inhalers and cartridge injectors if the student has a verified chronic medical condition and is deemed capable to self-administer. Such emergency medications do not include controlled substances (except in extraordinary conditions such as international field trips). Both an authorized prescriber and the parent need to provide written authorization for self-administration, and, under most circumstances, the school nurse needs to assess the student’s competency and must deem it safe and appropriate, looking at various factors related to the student’s knowledge and understanding of the medication plan. 10-212a-4.
In addition to coaches, athletic trainers, and paraprofessionals, the regulations also cover administration of medications in school readiness programs and before- and after-school programs which are run by local or regional boards of education and municipalities but exempt from licensure under the Department of Public Health. Such programs must also have policies and procedures for the administration of medications, developed with the input of the school medical advisor or licensed physician and the nursing supervisor, which determine the level of nursing services needed to ensure the safe administration of medications in the program, who may administer medications, whether a licensed nurse must be on site, and otherwise track the requirements for training, documentation and record-keeping applicable to schools. The regulations contemplate that parents will provide a separate supply of medication for use in the after-school program, but in situations where this is not possible, the medication supply may be transferred back and forth between the school nurse’s office and the after-school program on a daily basis. 10-212a-10(f).