Medicines Management – What adult social care providers can do to improve
The CQC’s report ‘Medicines in Health and Adult Social Care’ (6 June 2019), details learning from their regulatory activity in relation to medicines management. The purpose of the report is to encourage improvement across the sector by sharing common themes in relation to risk and also by highlighting examples of good practice.
A recent study estimated 237 million medication errors occurred in England last year. The CQC’s findings are based on an analysis of 55 inspection reports, 50 enforcement notices and 405 statutory notifications. The CQC confirms that between 1 April 2017 and 31 March 2018, they received 5,059 medicine-related statutory notifications from adult social care locations. Errors with ‘when required’ medicines, administration of incorrect dose, missed doses and errors linked to what community pharmacies had supplied to services were prevalent.
The CQC identified the following themes:
- Record Keeping
The key contributing factor was poor record keeping. The CQC found that Medication Administration Records (MARs) were either not completed or not completed accurately, and sometimes discontinued medicines or dosages which had been changed remained on MAR charts. Errors were more likely where charts were handwritten. Sometimes there were no corresponding charts to identify where transdermal patches or topical preparations had been administered.
- PRN (as needed) Medications
Staff did not always have enough information regarding how and when PRN medications should be used, or in relation to when external input may be required, i.e. GP review. As regards PRN for agitation or behaviour described as challenging, providers did not always have clear records of why PRN had been administered or what steps were taken to de-escalate a situation prior to administration. An example of good practice provided suggests that staff should have clear guidance regarding the steps that should be taken before PRN is administered.
- Storage and Disposal
Inspection reports detail medicine trolleys left unattended, creating a risk of accidental ingestion, and medicine stored at incorrect temperatures which may risk them becoming unfit to use.
- Covert administration and Capacity
The CQC found that Providers did not always comply with the requirements of the Mental Capacity Act 2005, Capacity assessments and best interests decisions had not always been carried out for people receiving medication covertly. The CQC reports on a person centred sticker reminder system for a resident who required medication for Parkinson’s symptoms at regular intervals.
NICE guidance states that staff should have an annual review of skills and competence. Concerns also extended to registered managers who did not maintain an up to date understanding of legislation and best practice.
- Policy and Audit
Providers should have a policy based on current legislation and best available evidence. Some providers did not have a policy or had one which had not been updated for some time. The CQC also found ineffective systems to monitor quality and drive improvement.
Actions for Adult Social Care Providers:
Based on the risks identified, the CQC sets out the following actions and considerations for providers:
- Adopt best practice guidance, specifically NICE guidance.
- Consider having an attached or named pharmacist to support staff.
- Train staff and assess competence, as an ongoing priority. It should be clear who is responsible for the training of staff and that training is kept up to date.
- Have clarity in relation to who has clinical responsibility and oversight of medicines management. Responsibility should be clear in contracts that commissioners issue to providers.
- It is noted that the new role of nursing associate may help to ease pressure on nurses, but providers must make sure they are deployed safely with appropriate supervision.
- The CQC highlight that adopting NHS England initiatives such as Enhanced Health in Care Homes and Medicines Optimisation in Care Homes can help drive improvement by involving pharmacists and providing joined up care to residents.
The full report can be accessed here.
Further CQC guidance regarding medicines management can be found at ‘Medicines: information for adult social care services’, (which has replaced the FAQ page).
This briefing is for guidance purposes only. RadcliffesLeBrasseur LLP accepts no responsibility or liability whatsoever for any action taken or not taken in relation to this note and recommends that appropriate legal advice be taken having regard to a client's own particular circumstances.