LIC 622: Centrally Stored Medication and Destruction Record

The licensee is responsible for the medication record. Title 22 §87465(h)(6) says "the licensee shall be responsible for assuring that a record of centrally stored prescription medications for each resident is maintained" ^[2]. It does not say which staff member writes each line. The Part I header of the form has the facility name and number, the resident's name, admission date, attending physician and administrator, and the instructions say medication records are kept "for each client/resident" ^[1].

The administrator and one other adult destroy medication, and both sign. For an RCFE, the destruction section says medication "must be destroyed by the administrator and one other adult who is not a resident of the RCFE, in the RCFE" ^[1]. §87465(i) says the same: "destroyed in the facility by the facility administrator and one other adult who is not a resident. Both shall sign a record" ^[2]. The witness can be any adult who is not a resident.

Read the RCFE paragraph, not the others. Part II of the form has three paragraphs: one for other facility types, one for RCFCIs (residential care facilities for the chronically ill) and one for RCFEs. The first paragraph allows a "designated representative" and requires destruction records to be kept for at least one year. Neither applies to an RCFE. The signature column heading still reads "Administrator or Designated Representative", but for an RCFE both the form's RCFE paragraph and §87465(i) name the administrator ^[1][2].

No number of days appears in the form or in §87465. The text gives these triggers and retention periods instead ^[1][2]:

• Medication record (Part I): §87465(h)(6) lists "the date filled" and the form has a "Date Filled" column, so a reasonable reading is one line for each fill of a centrally stored prescription. §87465(h)(1) lists when a medication must be stored centrally: it needs refrigeration and the resident has no private refrigerator, a physician finds it hazardous in the resident's own hands, or a physician, the administrator or the Department finds it a safety hazard to others. Keep the record "for at least one year" ^[1][2].
• Destruction record (Part II): destroy the medication when it is "not taken with the resident upon termination of services, not returned to the issuing pharmacy, nor retained in the facility as ordered by the resident's physician and documented in the resident's record nor disposed of according to the hospice's established procedures or which are otherwise to be disposed of" ^[2]. Keep the signed record "for at least three years" ^[1][2].

When the periods start. Neither the form nor §87465 says what the one year or the three years count from ^[1][2].

Two retention periods. §87506(b)(14) lists "Current centrally stored medications" among the contents of each resident's record, and §87506(e) says resident records are kept "a minimum of three (3) years following termination of service to the resident" ^[3]. §87465(h)(6) and the form say at least one year for the medication record. Neither section says which one governs. Ask your licensing analyst if you want either answer in writing.

§87465 does not name a place for these records. §87506 does for the resident's record. The licensee must keep it "in the facility or in a central administrative location readily available to facility staff and to licensing agency staff" ^[3]. Current centrally stored medications are on its list of contents ^[3]. The licensee also stores the record and keeps it confidential ^[3].

The destruction record is not on §87506's list of contents. The text does not say whether it sits in the resident's record or in a facility file. It does say who must sign it and how long to keep it ^[2].

Licensing can inspect and copy. Resident records "shall be available to the licensing agency to inspect, audit, and copy upon demand during normal business hours." If a licensing representative removes records, they must list them, leave you a signed copy of the list, and return the records "within three business days" ^[3]. For current residents, §87506(d)(1)(H) says licensing "shall not remove" the "Records of current medications" "unless the same information is otherwise readily available in another document or format" ^[3].

Storage of the medication itself. Centrally stored medication is "kept in a safe and locked place that is not accessible to persons other than employees responsible for the supervision of the centrally stored medication" ^[2].

Section 87465(h) and (i) set these requirements ^[2]:

• The six items on each resident's medication record. §87465(h)(6) lists them: the resident's name, the prescribing physician, the drug name, strength and quantity, the date filled, the prescription number and issuing pharmacy, and any instructions for control and custody ^[2]. The form's columns, with the resident name at the top of page 1, cover each one ^[1].
• Original containers and labels. "Each resident's medication shall be stored in its originally received container. No medications shall be transferred between containers." Each container carries the resident's name, the prescribing physician, the drug name, strength and quantity, the date filled, the prescription number and pharmacy, the expiration date and the number of refills ^[2]. The section also says "No persons other than the dispensing pharmacist shall alter a prescription label" ^[2].
• A locked place with limited access ^[2].
• A destruction record with both signatures and four items. §87465(i) lists the resident's name, the prescription number and pharmacy name, the drug name, strength and quantity destroyed, and the date of destruction ^[2].

Where the form and Title 22 differ in detail. Check each against the text when you fill out the form:

• Resident name on the destruction record. §87465(i)(1) requires "name of the resident" ^[2]. Page 1 of the form has a resident "Name:" field, but the destruction table on pages 3 and 4 has no name column ^[1]. Write the resident's name beside each entry.
• Who may open the locked storage. The form says "authorized individuals". §87465(h)(2) says "employees responsible for the supervision of the centrally stored medication" ^[1][2].
• Extra form columns. The form has "Date Started", "Expiration Date" and "No. of Refills" columns. §87465(h)(6) lists none of them, though §87465(h)(3) puts expiration date and number of refills on the container ^[1][2].
• When to destroy. The form's RCFE list of cases ends "or not otherwise disposed of". §87465(i) says "or which are otherwise to be disposed of" ^[1][2].