Medication recording and the use of multi-compartment aids.

NICE guidance on medication management in care homes and in the community say that records are required in respect of support provided for people’s medication.

Ref NICE SC1 says “Providers of adult care homes must ensure that records are made and kept when adult residents are supplied with medicines for taking themselves (self-administration), or when residents are reminded to take their medicines themselves”

NICE NG67 says “Care workers must record the medicines support given to a person for each individual medicine on every occasion, in line with Regulation 17 of The Health and Social Care Act 2008 (Regulated Activities) Regulations 2014. This includes details of all support for prescribed and over-the-counter medicines, such as:

·        reminding a person to take their medicine

·        giving the person their medicine

·        recording whether the person has taken or declined their medicine “

NICE NG67 defines support as “Any support that enables a person to manage their medicines. This varies for different people depending on their specific needs.”. 

One issue which arises is that of whether a record is required when medicines are prompted, from the above, it is pretty clear that a record is required in respect of all medicines for which support is provided in the community and all medicines taken by a person who lives in a care home, the latter is irrespective of whether the person self administers, is reminded (prompting) or has their medication administered by the care home.

The CQC provide some further guidance on this subject in their FAQ on medication, in the FAQ on Administering medicines in home care agencies, it says:-

• Care workers should record each time they provide medicine support. The record should include who administered the medicine and whether a medicine was taken or declined.
• Medicines support is any support that enables a person to manage their medicines. In practical terms, this covers:

1. prompting or reminding people to take their medicines
2. helping people remove medicines from packaging
3. administering some or all of a person’s medicines

• There is no need to keep records when the person is managing their medicines themselves.

This is consistent with the NICE guidance that a record is required except when the person lives in the community and manages their medication independently with NO IMPUT from the care provider.

In the CQC FAQ Self-administered medicines in care homes, it says:-

• You must keep records when:

1.   you supply medicines (including controlled drugs) for self-administration
2. you remind people to take their medicines themselves

• Staff do not need to fill in the administration section of the MAR chart. The chart must show that the person self-administers. It should also show how you check adherence.

The significance of this is that even when the person self administers, if they live in a care home there must be a record of their medications and that staff have checked that the person has self administered correctly.

NICE recommends that printed MARs should be used where possible. These should include:

·        the name of the person

·        the name, formulation and strength of the medicine(s)

·        how often or the time the medicine should be taken

·        how the medicine is taken or used (route of administration)

·        the name of the person’s GP practice

·        any stop or review date

·        any additional information, such as specific instructions for giving a medicine.

Many medication procedures devised by care providers and local authorities refer to medications supplied in blister packs, dossette boxes etc. These are called multi-compartment aids. Such polices often require only one initial to be made when medication is administered from the multi-compartment aid. This is contrary to the guidance from NICE and the CQC. In fact the CQC have issued guidance for both care homes and home care on this very subject.

The guidance for care homes says “They should not be the first choice intervention to help people manage their medicines.”, it also goes on to specify a number of considerations that care homes must take into account when choosing a medication system. These include:

·        other methods of support which may constitute a reasonable adjustment

·        medicines may be unstable outside of the manufacturers original packaging

·        staff must be able to identify which tablet is which, this is extremely difficult if all of the tablets are in the same container or compartment in the blister pack

In home care settings the CQC FAQ covers many of the same issues which arise in care homes. It also refers to NICE NG67 which ) states:

“Consider using a monitored dosage system only when an assessment by a health professional (for example, a pharmacist) has been carried out, in line with the Equality Act 2010, and a specific need has been identified to support medicines adherence. Take account of the person's needs and preferences and involve the person and/or their family members or carers and the social care provider in decision-making.”

The recently introduced CQC annual PIR requires providers to supply details of how many medication administration errors have occurred in the previous 12 months and how many medication recoding errors have occurred. A recoding error includes an inaccurate MAR chart. This means that a MAR chart which does not list each medication as recorded on the pharmacy label would be regarded as a medication recording error.

To conclude, care providers should consider the following actions:-

1.      Check that your policies and procedures are consistent with the CQC and NICE guidance

2.      Check that staff are following your procedures correctly

3.      Consider if the use of multi-compartment aids is appropriate and that they are a “reasonable adjustment” and that other methods have been considered.

4.      Audit MAR charts to ensure that they are completed in a way which matches the NICE guidance

5.      Audit MAR charts to identify and collate data on:

a.      Medication administration errors

b.      Medication recording errors

6.      Provide those who manage medication in the service (the Medication Lead) with suitable training

7.      Provide staff who provide medication support with suitable training

8.      Assess the competence of those who manage and those who administer medication

9.      Carry out a review of the skills, training and competence of those who manage or administer medication at least annually or more often if there is a medication error.