In New Mexico it is exactly as Ann described. We cannot per state pharmacy rules repackage medications into SAT packets for weekend dosing without a pharmacist or MD physically signing the packets/bottles. That becomes dispensing medications and is not allowed. For DOT workers or others who may be supervising DOT - the patient must open the bottle of medications and give themselves or (child) the medications while the DOT worker observes the dosage. Of course RNs can administer medications just as we would in a hospital environment.

Not being able to send SAT packages for weekend dosing is inconvenient and difficult to manage. Wish there was an easier way to do so!

From: TB nurse communication <nobody@simplelists.com>
Sent: Monday, September 3, 2018 6:22 PM
To: tbnurses@ntca.simplelists.com
Subject: Daily digest for tbnurses@ntca.simplelists.com

(Previous discussion continued)
Re: Daily digest for tbnurses@ntca.simplelists.com - Scarpita - CDPHE, Ann (03 Sep 2018 11:15 EDT)

Re: Daily digest for tbnurses@ntca.simplelists.com by Scarpita - CDPHE, Ann (03 Sep 2018 11:15 EDT)
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Good Morning, All and Happy Labor Day!

Your question is a good one. Something I believe we have all questioned ourselves at some point. I have looked into this in the two states I have worked and as I understand the laws and our limitations in scopes of practice surrounding dispensing of medications, RNs are not legally able to do legally do this. Only a pharmacist can dispense, including repackage and relabel medications. That said, you can immediately take from a bottle to a package if that is being given to the patient immediately by the RN who is doing the preparing (as you would in a SNF). You cannot put into smaller packages and give to the patient to take at a later date (weekend doses). You cannot prepare packages given by other nurses.

California may have a different law related to dispensing. I think Ann Raftery would know that answer (for California) but am not sure she is in the office this week. I am eager to hear if it does and any policies surrounding the application of RNs doing this in the field. It may be something we could propose expanding in other states.

So, I am sorry, I don't have what you are seeking and I commented but I believe you are bringing up a VERY good question and again, I am eager to hear more weigh in. For anyone sharing policies, procedures or protocols around this, I would like to ask that they touch on how they arrived at those and if their state has laws which allow nurses to dispense (i.e. different dispensing definition).

Hope you all have a superb Labor Day!

Respectfully,

~Ann

Ann Scarpita BSN, MPH

TB Nurse Consultant

Tuberculosis Program

Colorado Department of Public Health and Environment

4300 Cherry Creek Drive South, Denver, CO 80246

P 303.692.2656| F 303.759.5538

ann.scarpita@state.co.us

www.colorado.gov/cdphe/tb

"Wisdom is knowing the right path. Integrity is taking it." ~M.H. McKee

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On Fri, Aug 31, 2018 at 6:47 PM, TB nurse communication <nobody@simplelists.com> wrote:

Repacking Medications - Katie Kelsch (31 Aug 2018 11:16 EDT) Repacking Medications by Katie Kelsch (31 Aug 2018 11:16 EDT)
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Hi all,

This is for small/medium size counties, without a chest clinic and without a pharmacy. We are looking for Policies and Procedures around RNs repacking medications in to the DOT Packets. We receive the medications from our patients (filled at commercial pharmacies like CVS or Walgreens). We then create individual DOT packets in small plastic envelopes. Some concerns/questions that have come up are focused around:

· Labeling

· Child Poisoning Prevention Act

· The actual physical repackaging of medication

Thank you all! Have a safe Labor Day weekend.

Katie

Katie Kelsch, BSN, RN, PHN

Senior Public Health Nurse

Yolo County Health and Human Services Agency

137 N. Cottonwood Street

Woodland, CA 95695

Office: 530-666-8339 (direct)

Fax: 530-669-1549 (confidential)

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