Title:  The Role of the Licensed Nurse in the Department of Public Health Medication Administration Program

Advisory Ruling Number: 9401


The Massachusetts Board of Registration in Nursing (Board) is created and authorized by Massachusetts General Laws (M.G.L.) c. 13, §§ 13, 14, 14A, 15 and 15D, and G.L. c. 112, §§ 74 through 81C to protect the health, safety, and welfare of the citizens of the Commonwealth through the regulation of nursing practice and education.  In addition, M.G.L. c.30A, § 8 authorizes the Board to make advisory rulings with respect to the applicability to any person, property or state of facts of any statute or regulation enforced or administered by the Board.  Each nurse is required to practice in accordance with accepted standards of practice and is responsible and accountable for his or her nursing judgments, actions, and competency.  The Board’s regulation at 244 CMR 9.03(6) requires all nurses to comply with any other law and regulation related to licensure and practice.

Date Issued:  February 16, 1994

Date Revised:  May 14, 1997, November 12, 1997, July 10, 2002, July 14, 2010, September 11, 2013, June 8, 2016

Scope of Practice:  Registered Nurse, Licensed Practical Nurse


To guide the practice of the registered nurse (RN) who is employed specifically to provide training, consultation or monitoring within the context of the MA Department of Public Health (DPH) Medication Administration Program (MAP).  To guide the practice of the licensed practical nurse (LPN) who is employed to provide training in accordance with approved MAP policies and procedures.

Established at 105 CMR 700.003(F) and under the oversight of the DPH Drug Control Program, the MAP is a direct authorization, non-nurse delegation model of service delivery in a DPH-registered “Community Program.”  For the purposes of this Advisory Ruling, “Community Program” refers to any residential or day program registered with the Department of Public Health Drug Control Program and funded, operated, or licensed by the MA Department of Mental Health (DMH), Department of Developmental Services (DDS) or Department of Children and Families (DCF) with the exception of programs funded under Title XIX of the Social Security Act. This advisory ruling does not apply to programs that are not funded, operated or licensed by DMH, DCF and/or DDS.


The nurse licensed by the Massachusetts Board of Registration in Nursing (Board) is expected to engage in the practice of nursing in accordance with accepted standards of practice. Nurses must only assume those duties and responsibilities within the scope of practice for which they have acquired and maintained necessary knowledge, skills, and abilities.

It is the Board’s position that licensed nurses, when providing training, consultation, or monitoring within the MAP:

  • Do not bear responsibility and accountability for the outcome of the medication administration practice of the MAP-certified unlicensed community program staff that the licensed nurse has taught;
  • Does retain responsibility and accountability for his or her nursing judgments, actions, and competence for the content taught to unlicensed staff;
  • Meet applicable requirements for a trainer established jointly by the DPH and the DMH, DDS or DCF to instruct the didactic and practice components of the standardized MAP training curriculum leading to MAP certification;
  • May provide or arrange for technical assistance and advice when questions arise regarding appropriate administration practices or the effects of medications, including, but not limited to
    • Transcribing orders from a duly authorized prescriber;
    • Ordering medications from pharmacy;
    • Procuring;
    • Storing and destroying medications; and
    • Documenting all related activities;
  • Must direct or refer clinical inquiries from community program staff related to an unanticipated change in medical condition or change to medication order to the appropriate duly authorized prescriber in accordance with approved DPH policies; and
  • In the event that an event involving medication administration is inconsistent with a duly authorized prescriber’s order or anticipated outcome, may recommend action consistent with approved DPH policies, e.g., a healthcare provider, clinic, or emergency room visit.  It is not within the scope of practice of the RN or LPN to implement recommendations (e.g., order lab work, order hospitalization, change a medication order) prior to confirmation from a duly authorized prescriber.



104 CMR 28.00: Licensing and Operational Standards for Community Programs

105 CMR 700.000: Implementation of M.G.L. c. 94C

115 CMR 5.00: Standards to Promote Dignity

Medication Administration Program Policy Manual http://www.mass.gov/eohhs/docs/dph/quality/drugcontrol/map/map-policy-manual.pdf

This information is provided by the Division of Health Professions Licensure within the Department of Public Health.