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DHS COVID-19 PROVIDER GUIDANCE // ODP

Frequently Asked Questions: Modifications to Medication Administration Course Requirements as a Result of the COVID-19 Pandemic

Updated: December 15, 2020; Issued: October 14, 2020 

Audience

All Stakeholders Providers whose staff, contractors or consultants are required by 55 Pa. Code §§ 2380.129, 2390.198, 6100.468, 6400.169 or 6500.139 to take medication administration training and other interested parties.

Discussion

Per ODP Announcement 20-032, 55 Pa. Code Chapters 2380, 2390, 6100, and 6400 provide that a staff person can administer medications to individuals if the staff person successfully completes an ODP-approved medication administration course. A “standard” medication administration course is required to administer medications in Community Homes, Adult Training Facilities, and Vocational Facilities. A modified version of the course is available for life sharers and service locations that are not licensed by ODP.

Due to the COVID-19 pandemic, ODP allowed staff who are required to take the Standard Medication Administration Training Course (“Standard Course”) to take the Modified Medication Training Course (“Modified Course”) until December 31, 2020. Because the pandemic is ongoing, staff can continue to take the Modified Course in place of the Standard Course until June 30, 2021.

    1. The following must occur prior to a staff person administering medications:
          • The staff must complete the Modified Course online;
          • The staff must be observed administering medications four times by a Certified Medication Administration Trainer or Certified Medication Administration Practicum Observer, unless a trainer or observer is not available due to the COVID-19 pandemic. Observation may be conducted in-person or remotely using video interface technology. Remote observation is encouraged to maintain social distancing; and
          • The staff must be observed applying proper handwashing and gloving techniques one time by a Certified Medication Administration Trainer. Observation may be conducted in-person or remotely using video telecommunication technology. Remote observation is encouraged to maintain social distancing.
    2. Staff who have completed the initial requirements to begin administering medications as above must also comply with same the annual practicum requirements as those staff who have completed the standard medication administration training course. These requirements are:
          • Ensure observations of medication administrators occur two times annually by a Certified Medication Administration Trainer or Certified Medication Administration Practicum Observer. Observations of the medication administrations may be conducted in-person or remotely using video telecommunications technology. Remote observation is encouraged to maintain social distancing; and
          • Ensure Medication Record Reviews for the medication administrator occur two times annually by a Certified Medication Administration Trainer or Certified Medication Administration Practicum Observer. Medication Record Reviews of the medication administrations may be conducted in-person or remotely using video telecommunications technology. Remote reviews are encouraged whenever possible to maintain social distancing.

Providers must retain record of staff’s completion of the Modified Medication Administration Training Course by retaining a copy of the certificate of completion.

Questions and Responses

Below are frequently asked questions (FAQs) relating to medication administration requirements that were modified as a result of the COVID-19 pandemic. These questions and responses apply to both new and current staff unless otherwise indicated.

​Question
Response

1. ODP Announcement 20-032 clarified that the Modified Medication Administration Training Course is acceptable in lieu of the standard course for new staff in licensed settings. Will staff who took the modified course have to take the standard course at some point?

​Yes. Providers may elect to use the modified course in lieu of the standard course until June 30, 2021. 

Any staff person who took the modified course in lieu of the standard course between the period of April 1, 2020 to June 30, 2021 must complete the standard course no later than December 31, 2021.

Any staff hired after June 30, 2021 must take the Standard Course. 

​2. A Medication Administration Practicum Observer must observe staff who took the modified course in lieu of the standard course performing the following activities two times annually:

    • Administering medication(s) to an individual, and
    • Properly documenting medication administration in the Medication Record  Observation of the two items above is called the “Annual Practicum.”

How long will staff who took the modified course in lieu of the standard course have to complete the Annual Practicum?

​As noted above, any staff person who took the modified course in lieu of the standard course between the period April 1, 2020 to June 30, 2021 must complete the Standard Course no later than December 31, 2021. An Annual Practicum must be completed within one year of completion of the Modified Course.

For example, a staff person who completed the Modified Course on August 15, 2020 must complete an Annual Practicum by August 15, 2021.

3. When do staff who were Certified Medication Administration Trainers before the pandemic and who administer medications have to complete their Annual Practicum?

​Staff who were Certified Medication Administration Trainers before the pandemic must complete their Annual Practicum based on the date the last practicum was completed.

4. ​In order to successfully complete either the modified or standard course, staff must be observed administering medication four times.

Will staff who took the modified course in lieu of the standard course have to be observed administering medications as a condition of completing the standard course?

​No. Staff persons who took the Modified Course in lieu of the Standard Course do not have to be observed administering medications as a condition of completing the Standard Course.

  • If staff successfully complete the Standard Course within one year of successful completion of the Modified Course, the four medication observations that occurred as part of the successful completion of the Modified Course are sufficient. A second set of four observed medication administrations is not required as a condition of completing the Standard Course.
  • If more than one year passes between successful completion of the Modified Course and the Standard Course, an Annual Practicum must have been completed within one year of completion of the Modified Course. The Annual Practicum is sufficient and a second set of four observed medication administrations is not required as a condition of completing the Standard Course.

​5. Can Medication Record Reviews and observations continue to be conducted remotely?

​Yes. Medication Record Reviews and observations of medication administration may continue to be conducted in person or remotely using live video telecommunications technology through June 30, 2021

Remote observation is encouraged to maintain social distancing. Proper handwashing and gloving techniques can also be observed using live video telecommunications technology. It is not acceptable to view video recordings of these events.

Documentation of the successful completion of Medication Record Reviews and medication administration observations for each staff person must be retained.

​6. Can training for non-oral routes of medication administration continue to be conducted remotely?

​Training for non-oral routes of medication administration that is permitted to be provided by a certified trainer can be conducted remotely using video telecommunication technology but must be live, not recorded.

​7. What is the status of Train the Trainer re-certification extensions?

​Certification for anyone who is currently a Certified Medication Administration Trainer was extended to September 30, 2020.

If recertification was not completed by September 30, 2020, the Certified Trainer must request an extension, which will be reviewed on a case-by-case basis. Certified Trainers will not be permitted to perform their tasks as a trainer without either an extension or a completed recertification.

​8. What is the status of Practicum Observer
re-certification extensions?

​Certification for anyone who is currently a Practicum Observer was extended to September 30, 2020.

If recertification was not completed by September 30, 2020, the Observer must request an extension, which will be reviewed on a case-by-case basis. Practicum Observers will not be permitted to perform requalifications without either an extension or a completed recertification.

​9. Life Sharing staff, consultants and contractors were required to complete the Modified Course by December 1, 2020. Has ODP considered delaying this requirement due to the COVID-19 pandemic? Some host families need assistance using technology to complete the course.

All staff, contractors and consultants who are required to successfully complete the Modified Course were required to do so by December 1, 2020. ODP will grant no further extensions for the successful completion of the Modified Course.