Option to Delegate
Under the regulations, schools have two options:
- Administration of prescription medications by licensed personnel only
- Delegation of the responsibility for administration of prescription medications to trained, nursing-supervised unlicensed school personnel, provided certain conditions are met and the school district or private school registers with the Department of Public Health.
Types of Registration for Delegation to Unlicensed Personnel
There are three forms of registration:
1. Full Delegation: School districts/schools may apply for permission to delegate the administration of prescription medications to unlicensed school personnel as determined by the school nurse, provided that certain requirements are met. These requirements include but are not limited to policy development, sufficient school nurses to provide supervision to unlicensed personnel, and attendance by the school nurses leader or nurse contact at a program on Medication Delegation in the School Setting. This train-the-trainer program is designed for school nurses who are responsible for training unlicensed school personnel to administer medications and is offered by the Department. Please check this website for program offerings.
The Full Delegation registration process is twofold:
- A programmatic approval by the School Health Unit results in the forwarding of your application to the Division of Food and Drugs for their approval;
- Final approval is issued by the Division of Food and Drugs/Drug Control Program. Please visit their website at www.mass.gov/eohhs/gov/departments/dph/programs/hcq/drug-control for additional information. Full delegation becomes effective for one year on the issuance of a certificate by the Division of Food and Drugs. There is an annual fee for this approval and certificate.
Renewal applications for full delegation will automatically be mailed by the School Health Unit three (3) months prior to a school district's registration expiration date.
2. Delegation on Field Trips Only: This is an expedited registration completed by the School Health Unit. The registration lasts for two years, does not require a fee, and pertains to field trips and other short-term special school events.
3. Delegation of Epinephrine by Auto-injector to Students with Diagnosed Life-Threatening Allergic Conditions: This is an expedited registration completed by the School Health Unit. The registration lasts two years and does not require a fee. Because of the numbers of children with life-threatening allergic conditions, the Massachusetts Department of Public Health and the Department of Education strongly recommend that all schools and school districts , public and private, register with the MDPH to train unlicensed personnel to administer epinephrine by auto-injector to students with diagnosed life-threatening allergic conditions.
How to Register
The school nurse leader or school nurse should mail or fax a written request on the school's letterhead for an application for registration to:
Department of Public Health
250 Washington Street, 5th Floor
Boston, MA 02108
After review and if approved, the Department issues the registration.
Questions regarding medication delegation and the registration process should be referred to the School Health Advisor in your region.