Medication Administration Frequently Asked Questions

These are some of the more frequently asked questions related to medication administration in schools.  This is not an exhaustive list. The Medication in School webpages also answer many questions.  Schools and nurses can also direct questions to MDH at school.health.school@state.mn.us or MDE at mde.healthyyouth@state.mn.us

Who is authorized to administer medication in schools?

A variety of individuals can administer medication in school (e.g., licensed school nurses (LSN)/registered nurses (RN), licensed practical nurses (LPN), unlicensed assistive personnel (UAP), secretaries, teachers, and principals). Parents/legal guardians should be aware of the medication process at the school their student attends. Parents/legal guardians are to provide the school with written authorization for school personnel to provide medication to their student according to Minnesota Statute § 121A.22 Subd. 1. 

Can a teaching assistant or secretary administer medication?

Yes. Secretary or other school personnel can administer medication or assist a child in the self- administration of medication when an RN/LSN has delegated medication administration to that person and guidelines are followed, including receipt of oral or written permission from a parent/legal guardian.

If the school has no nurse on staff, school policies and procedures must be developed to comply with Minnesota Statutes § Chapter 121A.22, Subd. 4. Everyone should follow the Six Rights of Medication Administration. A parent permission form should include the student’s name, date, medication name, amount, and instructions on dose, route, and when to take the medication.

Does a school board have to approve a policy regarding medication administration?

Yes, Minnesota Statute § Chapter 121A.22, Subd. 4, specifies that drugs and medicine must be administered according to the directions on the label and, to the extent possible, in accordance with policies and rules of local boards of education and developed with health expertise.

May a school district apply for a variance from the requirements of the Nurse Practice Act?

No. School districts should examine existing policies, procedures, and practices to ensure compliance with the Nurse Practice Act. Questions regarding compliance with the act can be directed to the Minnesota State Board of Nursing.

Can parents/legal guardians authorize school personnel to give medications to their child?

Yes. According to Minnesota Statutes § Chapter 121A.22, Subd. 1, school personnel can administer prescription drugs or medicine to a child at the request of the parent. The request can be either oral or in writing, but an oral request must be provided in writing within two school days.

Is it permissible for parents/legal guardians to come to school to give medication?

Yes, but only for their child. However, parents/legal guardians cannot be required to come to school to administer the child’s medication or perform a procedure.

Can a nurse provide OTC medication to students upon a parent’s request, according to labeling but without a prescriber’s authorization?

Yes, according to the Minnesota Attorney General’s Office. It is important to note, however, that the school nurse has the ultimate authority and responsibility to reject a parent’s request and to decline to administer an OTC medication if the nurse believes that such medication is unnecessary, inappropriate, or could lead to patient harm. Alternatively, the school nurse and/or school policy could require a physician’s order to administer the OTC medication.

Can parents/legal guardians train school staff on medications related to their child’s specific diagnosis (e.g., diabetes, epilepsy, asthma, or allergies)?

Parents/legal guardians can be a great source of knowledge regarding their individual child’s health condition and when the student needs and how the student takes his or her own medications. Parents/legal guardians have received information and education when their child was diagnosed and prescribed the medication; they live with and provide for the child at home; and they might have attended workshops or belong to advocacy organizations. It is appropriate for the schools to listen to and utilize parents’ knowledge to help accommodate their child in the school setting. A parent/guardian cannot delegate or assign medication administration to school staff.

Can teacher or other personnel administer epinephrine in an emergency if a child has an allergic reaction to a bee sting?

Yes, with or without nursing delegation and with appropriate training and supervision. Minnesota Statutes § Chapter 144.344 allows health services “to be rendered to minors of any age without the consent of a parent or legal guardian when, in the professional’s judgment, the risk to the minor’s life or health is of such a nature that treatment should be given without delay and the requirement of consent would result in delay or denial of treatment.”

Under Minnesota Statute § Chapter 121A.2207 “districts and schools may obtain and possess epinephrine auto injectors to be maintained and administered by school personnel to a student other individual if, in good faith it is determined that person is experiencing anaphylaxis regardless of whether the student or other individual has a prescription for an epinephrine auto- injector.”

How do you determine if a child is competent to self-administer medications?

Things to be considered include a physician’s/licensed health care provider evaluation and/or nursing assessment, parent/legal guardian authorization, and the student’s physical and mental development and age.

To assist in determining if a student is competent to self-administer medication, it might be useful to list criteria in Minnesota Administrative Rules 9505.0335, Subp. 1(A): “Capable of directing his or her own care” refers to a recipient’s functional impairment status as determined by the recipient’s ability to communicate: (1) orientation to person, place, and time; (2) an understanding of the recipient’s plan of care, including medications and medication schedule; (3) needs; and (4) an understanding of safety issues, including how to access emergency assistance.

Is training required for persons assisting with self-administration of medications?

Yes, training must be considered when a registered nurse delegates such assistance. Training is an essential part of delegation. Training ensures consistent and safe care of students. It is recommended that back-up personnel be trained at each school site. Training must be provided for school personnel who administer emergency medications such as quick-relief inhalers, Diastat™, or nasal seizure rescue medications, epinephrine auto injectors, and Glucagon™ or Baqsimi™.

Must the delegating nurse provide all the training of the UAP?

No. Some educational institutions and community colleges provide in-service or orientation programs that include the information and skills training needed to perform medication administration. The delegating nurse should ensure the competency of the individual trained; documentation of training and competencies should be maintained.

Can a student who has diabetes perform his/her own glucose monitoring and insulin administration, either by syringe or pump?

Yes. If not done by the student, it may be performed by a nurse or the RN/LSN may delegate to others who are trained to assist in the procedure. Consider the development of an IHP to better communicate actions and expectations.

As an LSN/RN, am I accountable for the acts of a UAP when I delegate medication administration to that individual?

Delegation standards require RN/LSNs, in keeping with their nursing scope of practice, to assess the student, determine the care needs of the student, determine whether the particular function is appropriate to delegate, determine whether the trained UAP has the skills needed to safely perform the task, and determine whether the appropriate supervision is available.

The trained UAP is responsible for performing the activity according to the delegation of the RN/LSN. If the UAP deviates from proper procedure and it is determined that the RN/LSN has appropriately delegated and trained the medication administration activity, the RN/LSN has fulfilled the duties of proper delegation.

May an LPN supervise or direct the nursing practice of LSNs/RNs?

No. Supervision of nursing personnel is not within the legal scope of practice of the LPN.

Can an LPN delegate medication administration to a UAP?

No. Delegation is not within the LPN’s scope of practice.

Can an LPN assign medication administration to another LPN and UAP?

Yes. Assignment of nursing tasks and activities are within the LPNs scope of practice. However, there are limitations to assignment. The type of medication administration must be within the LPNs scope of practice and training and the UAP must have had educational preparation in medication administration.  Nursing delegation explains assignment including applicable laws, rules, and scope of practice.

Must medication administration be re-delegated each day?

No. When medication administration is delegated, the LSN/RN should periodically assure the medication administration delegated is completed as directed.

Why is documentation stressed related to medication administration?

Documentation can be critical evidence in the event the delegation or delegated services are challenged legally. Appropriate documentation serves as additional protection for the delegating nurse, the UAP, and the student receiving the medication.

Can the task of medication administration by gastrostomy-tube, insulin pump, or injection be delegated?

Yes, by delegation from an RN/LSN. The decision to delegate belongs to the RN/LSN. School administrator cannot require the RN/LSN to delegate. The RN/LSN will train and supervise the person to whom the medication administration is delegated. If the school has no nurse on staff, school policies and sound medical procedures must be developed in adherence to Minnesota Statutes § Chapter121A.22, Subd. 4.

Does the school district medication administration policy apply to summer school?

Yes, it can. It is best practice to utilize the same policy/procedure to ensure student safety. The school can choose to have a separate policy specific to summer-school activity. 

Can a nurse (RN or LPN) administer medication prescribed by a provider (MD, APRN, DDS, DO, PA) who is not licensed to practice in MN? Example. Student moves from Wisconsin to Minnesota, and has a prescription medication for seizure, anaphylaxis, oral medication, inhaler, etc. They do not yet have a provider in MN.

“Nothing in this section allows a nurse to perform a patient care procedure or technique at the direction of a physician, a podiatrist, a dentist, or an advanced practice registered nurse that is illegal in this state.”

Under the state boundaries consideration above, a nurse could administer the medication if the nurse can verify that the student has had an examination by that provider. Verification could be from a verbal conversation or written documentation such as clinic note, after visit summary or discharge summary that lists an examination and findings of the exam. However, APRN's will always need a MN license. The school nurse cannot assume an examination was completed just because you have a labeled prescription bottle with the medication.

This statute in the Nurse Practice Act is seen as a short-term solution until the student can establish care with a MN provider, who should then complete the provider authorization for medication administration in the school.

Does this apply to medically delegated procedures as well, such as g-tube feedings, tracheostomy cares, etc.? YES, the same standard applies.