Advisory Ruling  Transportation of Medication (to and from) MAP Site

Date:	04/04/2018
Referenced Sources:	Medication Administration Program (MAP)

The Department of Public Health (DPH) MAP Registered sites must establish, maintain and operate in accordance with policies that ensure that only properly trained and Certified personnel store and handle medications as set forth in federal and state laws including the MAP Policy Manual.

The Service Provider for the DPH MAP Registered site must ensure that MAP Certified staff transport medications only for the individuals¹ residing at the DPH MAP Registered site for which the MAP Certified staff formally works and only during the MAP Certified staff’s work hours.  MAP Certified staff must not transport medications for individuals residing outside of the staff’s work site or on the staff’s own time.

Transportation of medications off-site includes, but is not limited to:

• picking up medications from the pharmacy (MAP Policy 10-4 Storage and Labeling of Medications; MAP Policy 10-10 Transfer/Transport of Medications);  
• transferring medications from the DPH MAP registered site to/from another DPH MAP registered site, hospital, day program, respite, etc. (MAP Policy 10-10 Transfer/Transport of Medications);
• transporting sample medications from the Health Care Provider (MAP Policy 10-4 Storage and Labeling of Medications);
• transporting medications to individuals for subsequent administration off-site (MAP Policy 10-11 Administering Medication to individuals living in the Community (off registered-site/“backpacking”) Setting); and

transporting medications for individuals to receive on a LOA or vacation LOA with MAP Certified staff administering the prescribed medications (MAP Policy 11-2 Preparation of Medications for LOA).

¹ “Ultimate User” a person who lawfully possesses a controlled substance for his own use or for the use of a member of his household or for the use of a patient in a facility licensed by the department or for administering to an animal owned by him or by a member of his household. M.G.L. c. 94C, § 1 and 105 CMR 700.001

“Ultimate User” a person who has lawfully obtained, and who possesses, a controlled substance for his own use or for the use of a member of his household or for an animal owned by him or by a member of his household. 21 U.S.C. § 802(27)