How to Write an NDIS Medication Management Policy

Management of medication is one of the standards in the support provision environment division of the NDIS Practice Standards Core Module, which you'll be audited against if you're on the Certification pathway. The current indicators are in section 26 of the NDIS (Quality Indicators for NDIS Practice Standards) Guidelines 2018, and the standard applies to providers responsible for administering medication to participants.

The outcome is that each participant requiring medication is confident their provider administers, stores and monitors the effects of their medication and works to prevent errors or incidents. There are three indicators:

• Records clearly identify the medication and dosage required by each participant, including all information required to correctly identify the participant and to safely administer the medication.
• All workers responsible for administering medication understand the effects and side-effects of the medication and the steps to take in the event of an incident involving medication.
• All medications are stored safely and securely, can be easily identified and differentiated, and are only accessed by appropriately trained workers.

Your policy and procedure should set out how you meet each of these in the settings where you actually support participants. Keep it to the systems around medication (records, training, storage, incidents and reviews), as clinical decisions about medication belong with the participant's prescribers and pharmacist.

Medication records

The first indicator needs records that identify the participant, the medication and the dosage, and contain everything a worker needs to administer it safely. Your procedure should cover:

• where each participant's current medication information comes from (for example, the prescriber's instructions or a pharmacy-prepared medication chart)
• how workers record each administration, and what they record if a dose is refused, missed or withheld
• how changes to a participant's medication are received, checked and updated in the record, and how workers are told
• how you make sure the participant is correctly identified before medication is given

Worker knowledge and medication incidents

Workers responsible for administering medication need to understand the effects and side-effects of the medication they give, and also need to know what to do if an incident involving medication occurs.

Set out how workers are trained before they administer medication, how they're given information about each participant's medications (for example, the consumer medicine information from the pharmacist), and how you check their competency. Then describe the steps to take after a medication incident, such as a wrong dose, a missed dose, or a suspected reaction, including seeking medical advice and recording it through your incident management system. Check whether the incident also needs to be notified as a reportable incident.

Storage

The third indicator covers safe and secure storage, medications that can be easily identified and told apart, and access limited to appropriately trained workers. Describe where medication is kept in each setting you support people in, who can access it, and how you keep each participant's medication separate and labelled.

If you support people in their own homes, the storage arrangements may be the participant's choice rather than yours. Your policy can say how you'll work with the participant to keep medication safe while respecting that.

Polypharmacy

Polypharmacy isn't named in the quality indicators, but the NDIS Commission's Practice Alert: Polypharmacy (November 2020) links it directly to the Management of medication standard and the Code of Conduct.

The alert describes polypharmacy as often defined as the use of five or more medications, or two or more psychotropic medications, at the same time. It includes prescription, over-the-counter and complementary medicines. The alert notes that polypharmacy increases the risk of medication-related adverse effects and poorer health outcomes, and also that it may be the most appropriate treatment, particularly for people with multiple conditions.

The alert's recommended ways to support participants receiving polypharmacy include:

• arranging for a medical practitioner or pharmacist to review their medications every 3 to 6 months
• for participants taking five or more medications (or two or more antipsychotics), arranging a pharmacist review through the Home Medicines Review program
• keeping a record of when each participant's medications were last reviewed
• making sure participants, carers and support workers have ready access to a full list of the participant's current medicines
• making an appointment with a medical practitioner if you suspect a participant is experiencing adverse effects from their medications, particularly after a recent change

Build these into your policy. Name who is responsible for tracking review dates, where the full medication list is kept, and how workers raise a concern about possible side-effects. The alert also points to two Code of Conduct obligations: providing supports in a safe and competent manner with care and skill, and promptly raising and acting on concerns about matters that may affect the quality and safety of supports.

Medication and chemical restraint

Section 6 of the NDIS (Restrictive Practices and Behaviour Support) Rules 2018 defines chemical restraint as the use of medication or a chemical substance for the primary purpose of influencing a person's behaviour. It doesn't include medication prescribed by a medical practitioner for the treatment of, or to enable treatment of, a diagnosed mental disorder, physical illness or physical condition.

If a medication you administer is being used primarily to influence a participant's behaviour, it may be a regulated restrictive practice, with the registration, authorisation and behaviour support plan requirements that come with it. The Commission's Medication Purpose Form can be used with the participant's medical practitioner to clarify the purpose of a prescribed medication. Your policy should say how you'll identify medications that may be chemical restraint, and what you'll do when the purpose isn't clear.

Related standards

Other quality indicators might on medication depending on your services, and so consider cross-referencing your policies where relevant:

• Safe environment (section 24) requires protocols for each participant about responding to medical emergencies, training for workers in responding to them, and systems for escalation in urgent health situations.
• Responsive support provision (section 22) requires workers to be appropriately trained and to understand the participant's needs and preferences where a participant has specific needs requiring monitoring or daily support.
• Subcutaneous injections sit in Module 1 (High Intensity Daily Personal Activities), not this standard. If your workers give subcutaneous injections, that module applies as well.