Special Edition: All About Meds
School Health Training MCSR
Required for school nurses who plan to provide only epinephrine and/or opioid antagonist rescue training to unlicensed school personnel
School Health Delegation MCSR
Required for school nurses who plan to delegate administration of a broader variety of medications to unlicensed school personnel.
✅Emergency Medications Don't Require Consultation
Rescue inhalers
Epinephrine autoinjectors
Pre-dosed Glucagon
Pre-dosed anti-seizure via mucous membranes
Pre-dosed opioid antagonists
Medications that Cannot be Delegated
105 CMR 210.004 (A)(4) "Parenteral medications may not be delegated or administered by training, with the exception of epinephrine or injectable glucagon in an FDA-approved, pre-dosed autoinjector administered in accordance with the restrictions outlined in 105 CMR 210.000."
105 CMR 210.002 "Parenteral Medication means any medication administered in a manner other than by the digestive tract or topical application, as by intravenous, intramuscular, subcutaneous, or intradermal injection."
Examples of parenteral medications that cannot be delegated in the school setting: insulin
Medication Error Reporting
All medication errors "that are reportable to MDPH School Health Services via this form, under 105 CMR 210.009 (B) are "all medication errors requiring medical care or ongoing assessment."
Medication error reports can be submitted here
Epinephrine Administration Reporting
105 CMR 210.010(A)(7)(j) and 105 CMR 210.009(C) require the reporting of epinephrine administration in schools. This applies to all Massachusetts schools, including both nonpublic and public, during "regular school activities". 105 CMR 210 states that "Regular School Activities means all instructional/academic activities, as well as all activities organized or sanctioned by the school including, but not limited to, day and overnight field trips, school-provided transportation, interscholastic sporting events, after school or extracurricular clubs or organizations, and proms or other social events organized as part of the instructional/academic portion of the school."
Epinephrine Administration Reports can be submitted here
Opioid Antagonist Reporting
The Opioid Antagonist Reporting Form must be completed each time an emergency rescue opioid antagonist (ex: Narcan) is administered in accordance with 105 CMR 210.009(C) as noted in 105 CMR 210.011(A)(5)(b). This includes opioid antagonist administrations that were not due to a suspected overdose (ex: accidental discharge during training).
Opioid Antagonist Reports can be submitted here
Vitamins, Supplements, Etc
MA BORN Advisory Ruling Number: 9801 states that "Nurses who integrate homeopathy, herbal medicines and/or dietary supplements (a vitamin, a mineral, an herb or other botanical, an amino acid, a dietary substance for use by humans to supplement the diet by increasing the total daily intake, or a concentrate, metabolite, constituent, extract, or combinations of these ingredients[1]) into their practice require a prescription(s) from duly authorized prescribers identifying the minimum required elements[2] of a prescription prior to incorporation in the overall plan of care."
So, although vitamins, supplements, and the like do not fall under the 105 CMR 210 definition of a medication, the MA BORN Advisory 9801 provides further clarification.
You can find this advisory, as well as many others, here: MA BORN Advisory Rulings
Athletic Trainers
"Licensed athletic trainers are not independently authorized pursuant to the Controlled Substances Act to administer medications in school settings. Exceptions that would allow an athletic trainer to administer medications include:
1) The licensed athletic trainer also holds another license (e.g., physician, nurse, physician assistant) that independently authorizes them to administer medication. OR
2) The school nurse delegates their authority to administer medication, pursuant to 105 CMR 210.000, to the athletic trainer and provides appropriate training. OR
3) The athletic trainer has been trained to administer epinephrine per an individual student’s prescription under 105 CMR 210.000."
See the full advisory here
