Title: The Role of the Licensed Nurse as Trainer or Consultant for the Department of Public Health Medication Administration Program
(formerly Nursing Practice Related to Medication Administration)

Advisory Ruling Number: 9401

Authority: The Massachusetts Board of Registration in Nursing issues this Advisory Ruling on Nursing practice pursuant to Massachusetts General Laws (MGL) chapter 30A, section 8 and chapter 112, section 80B.

Date Issued: February 16, 1994

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

Scope of Practice: Registered Nurse, Licensed Practical Nurse

Purpose: To guide the practice of the Registered Nurse who is employed specifically to provide training and consultation within the context of the MA Department of Public Health (DPH) Medication Administration Program (MAP).  To guide the practice of the Licensed Practical Nurse 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 that is 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 is not applicable to programs that are not funded, operated or licensed by DMH, DCF and/or DDS.

Such practice must be in compliance M.G.L. c. 112, s. 80B, M.G.L. c. 94C; 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; 244 CMR 3.02 Responsibilities and Functions – Registered Nurse; 244 CMR 3.04 Responsibilities and Functions – Practical Nurse; 244 CMR 9.03(5) Adherence to Standards of Nursing Practice; 244 CMR 9.03(9) Responsibility and Accountability; 244 CMR 9.03 (10) Acts within the Scope of Practice; 244 CMR 9.03 (11) Performance of Techniques and Procedures; 244 CMR 9.03 (12) Competency; 244 CMR 9.03 (14) Asepsis and Infection Control; 244 CMR 9.03(35) Security of Controlled Substances; 244 CMR 9.03(38) Administration of Drugs; 244 CMR 9.03(39) Documentation of Controlled Substances; and 244 CMR 9.03(44) Documentation.

Advisory: 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. The nurse must only assume those duties and responsibilities within the scope of practice for which necessary knowledge, skills, and abilities have been acquired and maintained.

It is the Board’s current position that the licensed nurse, when providing training and consultation within the MAP:

  • Meets applicable requirements for a trainer established jointly by the DPH and the DMH, DDS or DCF in order to instruct the didactic and practice components of the standardized 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, ordering, procuring documenting, destroying and storing of medications pursuant to established policies and procedures; 
  • 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;
  • May recommend action consistent with approved DPH policies such as a physician, clinic, or emergency room visit, or other intervention associated with an occurrence involving medication administration that is inconsistent with a duly authorized prescriber’s prescription or anticipated outcome. It is not within the scope of practice of the Registered Nurse or Licensed Practical Nurse to order implementation of such recommendations (e.g., order lab work, order hospitalization, change a medication order); and
  • Does 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. The licensed nurse is responsible and accountable for his or her nursing judgments, actions, and competence related to teaching unlicensed staff.

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