Medication Guidelines for Colorado School and Child Care Settings

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Revised July 2024

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Overview

According to the National Center for Children’s Health (2022), it is estimated in the United States, more than 40% of school-aged children and adolescents have at least one chronic health condition. Medication administration within the school or child care setting is critical because medications keep children in school and ready to learn. Medication administration in these environments is complex due to a variety of factors, including federal and state disability laws, new pharmaceutical and medical technologies, evolving mental and medical health practices, fewer full-time school nurses and child care health consultants, and increasing numbers of children with complex and routine health needs. Children who require medications to fully benefit from a Free Appropriate Public Education (FAPE) are protected by federal and state disability laws including the Individuals with Disabilities Education Act (IDEA), Exceptional Children's Education Act (ECEA) and Section 504 of the American with Disabilities Act. Students might require medications during school and school sponsored activities for many reasons, including but not limited to:

• Chronic conditions requiring maintenance medication to benefit from classroom instruction
• Acute, but temporary medical needs that require medicine during the day, such as an antibiotic for an infection
• Conditions that might require emergency medication, such as a quick relief inhaler for asthma

School Nurses, and Child Care Health Consultants (CCHC) have the educational background, expertise, and licensure required to direct the administration of medications in group settings. Medications, when administered and used appropriately, can improve children’s health but may be harmful if administered incorrectly. If a child needs specific medication during the course of the day to attend school or child care and benefit from their educational program, it is in the school’s and child care’s interest to consider the appropriate accommodations.

Definitions:

• School Nurse:  Per Colorado Department of Education (CDE), a school nurse is an individual licensed to practice as a Registered Nurse (RN) in Colorado who is also licensed as a CDE Special Service Provider with an endorsement as a school nurse, per the Exceptional Children's Educational Act (ECEA) Rules March 2016, 1 CCR 301-8, 2.37(3)(m)
• Child Care Health Consultant (CCHC): Per Healthy Child Care Colorado, a CCHC must hold a current Colorado license as a registered nurse, pediatric nurse practitioner, family nurse practitioner, or physician with knowledge and experience in maternal and child health and apply for CCHC Qualifications in the Professional Development Information System (PDIS).

This document provides guidance and best practices for school nurses in the Colorado K-12 public school setting and for Child Care Health Consultants in licensed child care settings, including preschools. The terms “school nurse” and “child care health consultant” are used interchangeably, as are the terms “school” and “child care programs.”

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Legal Considerations & Policies

If a student requires medication in order to access a FAPE under federal and state disability laws, then the administration of such medication is an appropriate “related” or support service as defined by federal law (IDEA). If necessary, the service should be incorporated into the student’s Individualized Education Program  (IEP) or Section 504 accommodation plan. State laws, regulations and local district policies define how medication should be administered to students for whom this is a related service and for students whose needs for medication may be for a temporary condition.

To ensure student safety and protect school and staff from liability, schools must provide for the safe administration of medication to students per district policy.  The school nurse must train and delegate the task of medication administration to a school staff member in the event that the school nurse is not accessible. For more information on delegation, refer to the Delegation Considerations for the Colorado School Nurse and Child Care Health Consultant.

School staff should be trained using a state approved training that covers the basic tenets of medication administration. Licensed Child Care settings must have at least one person on site at all times who has successfully completed the state approved Medication Administration Training (MAT) and is delegated by their school nurse or CCHC.  

According to the Colorado Nurse Practice Act, it is unlawful for any person to practice as a practical or professional nurse unless licensed to practice that profession; therefore, administering medications to the child in schools and child care settings without a valid nursing license is unauthorized practice.  (C.R.S. 12-255-125).  Colorado permits a registered nurse to delegate nursing tasks of a routine and repetitive nature, including the administration of medication, that do not require nursing judgment to unlicensed persons who have been trained. The rules and regulations implementing the law allow for delegation of the administration of medication in schools and child care settings can be found in Chapter 13 Rules for Delegation. (3 CCR 716-1).

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Essential Components of Medication Administration in Schools or Childcare

Category column is hyperlinked to full section of guidance for more information.

Category	Summary	Statutes/ Rules
Policy	Medications must be administered in accordance with school policy. There must be a reason to administer the medication when the child is at school or child care.	CRS 22-1-119 1 CCR 301-113
Medication Orders & Consent	The parent/guardian must provide written permission (consent) to administer a prescription or over-the-counter medication. Written orders from the healthcare provider and parent/guardian consent must be in place. Written orders from the provider and parental consent are obtained per district policy (annually or at the beginning of each school year). Orders should include provider signature, name of medication, dosage, purpose of the medication, time of day medication is given, duration, and possible side effects.	CRS 12-255-132 CRS 22-1-119 12 CCR 2509-8
Training & Delegation	Medication may be legally given only by personnel who have participated in an appropriate training and to whom a registered nurse has delegated the task of administering medication. Delegation must not exceed one school year. In some instances, the law allows for training without delegation.	CRS 22-1-119 CRS 2-255-131 3 CCR 716-1 1 CCR 301-68 1 CCR 301-113 12 CCR 2509-8
Storage	The non-expired medication must be in the original labeled container and stored properly.	CRS 22-1-119 6 CCR 1010-6 6 CCR 110-7 12 CCR 2509-8
Documentation	School personnel must keep an individual record of any medication administered, or an explanation if an ordered medication is not administered.	CRS 22-1-119 3 CCR 716-1

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Role of the Nurse in Medication Administration

The responsibility of the school nurse/CCHC is to assure that procedures are in place for the safe delivery of all prescription and over-the-counter medications, including administration, documentation, storage, proper disposal, and follow-up/evaluation.

Appropriate activities include:

Laws & Rules

• Reviewing and understanding state laws, regulations, and rules related to medication administration, delegation, and ongoing supervision.

Policies & Procedures

• Reviewing existing local school district policies, procedures, and forms related to best medication and suggesting revisions as necessary to comply with federal and state mandates, nursing standards, and current best practices.
• Establishing procedures for training, ongoing supervision, and evaluation of unlicensed assistive personnel for any delegation.
• Establishing procedures for reauthorization of the medication orders and parental consent form obtained per district policy (annually or at the beginning of each school year).
• Establishing and ensuring documentation and quality control systems for storage and administration of medications on-site and off-site at school-sponsored events.
• Ensuring the proper disposal of expired and discontinued medications.
• Communicating medication administration policies and procedures on a regular basis to students, parents, and school staff.

Orders, Consent & Plans

• Ensuring medication administration is accompanied by proper written parental/guardian permission and health care provider orders in accordance with state rules and district policy, annually or at the beginning of each school year, and updated if medication orders change.
• Working with school staff to clarify language referring to medication administration in all individualized education programs (IEPs and 504 plans), individualized healthcare plans (IHPs), and/or emergency healthcare plans.
• Assuring school transportation, field trips and emergency/disaster plans consider medication needs.

Training, Delegation & Administration

• Training school staff to recognize signs and symptoms of medication side effects, adverse reactions and/or problems such as overdoses, skipped dosage(s), and necessary action steps.
• Providing delegation to administer medications.
• Document special limitations or orders to delegation instructions (e.g. mixing instructions, administration routes, instructions to administer medication before/after eating, etc).
• Reviewing pharmacology and dosage of medications to be administered.
• Observing and evaluating student health status and response to medication. Initial doses of medication should be administered at home if possible, by the parent, to observe for adverse reactions or side effects.
• Determine the ability of students to self-carry.
• Developing a communication plan with parent, healthcare provider and student to address challenges with self-administration.

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Medication Administration Training (MAT)

Medication Administration Training: A Training for Unlicensed Assistive Personnel in Public, Charter, Private and Parochial Schools, Child Care Centers, Preschools, School-Age Child Care, Residential Camps, Day Camps, and Family Child Care Homes, 2017, Sixth Edition, often referred to as the Medication Administration Training or MAT, is the required training for staff in the licensed childcare setting (12 CCR 2509-8) to administer routine medications. This is also the state-approved training for staff in the school setting for routine medication administration. This training includes information about delegating, supervising, monitoring, and documenting administration of routine medication. The MAT course can be taken in person, or hybrid.

• Per the MAT facilitator guide, page 7, it is required to be completed every three years (or more often, as the CCHC or school nurse requires). An annual review, assessment of delegatee competency, and re-delegation is required.
• Steps for accessing the Medication Administration Training are on the CDE School Nursing & Health Training Tools webpage. 
• Note: The MAT course does not cover all medications that may be given in schools or child care centers. Medications not covered in the MAT require individualized training and, when required, delegation from the school nurse or CCHC.

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Delegation

Delegation of the task of medication administration must occur after the school staff has successfully completed training (3 CCR 716-1).  See the CDE Delegation Considerations for the Colorado School Nurse and Child Care Health Consultant for more information on delegation. 

Administration of stock Epinephrine and/or Naloxone by designated personnel is not a delegated nursing function and therefore does not require nursing delegation (3 CCR 716-1). 

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Medication Orders & Consent

Written orders from the health care provider are obtained annually per district policy.  Also, the parent/guardian must provide written permission (consent) to administer a prescription or over-the-counter medication.  

The written order by the person with prescriptive authority shall include:

• Child's name;
• Licensed prescribing practitioner name, telephone number, and signature;
• Date authorized;
• Name of medication and dosage;
• Time of day medication is to be given;
• Route of medication;
• Length of time the medication is to be given;
• Reason for medication (unless this information needs to remain confidential);
• Side effects or reactions to watch for; and
• Special Instructions
   

The State Board of Pharmacy’s Prescriptive/Drug Procurement Authority Table summarizes who can prescribe medications in Colorado and includes:

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Procedure for Accepting Medications

When accepting medications, ensure that the following is in place:

1. Medication is in the original container
2. Container is labeled with the child’s name
3. Dosage instructions are included
4. Prescription medication bottles need to have a pharmacy label with:
   1. The name of medicine
   2. The time and route the medicine is to be given
   3. The date the medicine is to be stopped or the date the medication expires
   4. The health care provider’s name
   5. The pharmacy name and phone number
5. Over-the-counter medications need to have a label with:
   1. Name of the medication and the expiration date
   2. Directions for safe use
   3. The list of ingredients

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Documentation and Record Keeping

School health personnel should maintain accurate individualized daily records of medications administered, any special circumstances related to the procedure, and any unusual reaction or response. A separate medication log must be kept for each student and for each medication. It may be a paper or electronic log. If using a paper log, permanent ink must be used. This log becomes a permanent record and provides legal protection to those who administer medications in schools.

The log should contain:

• Student’s name;
• Name of the medication, dosage and route;
• Time medication should be given;
• Special instructions; and
• Name and initials of the individuals giving the medication.

A picture of the student attached to the log is helpful in assuring that the proper student gets the proper medication. Student confidentiality must be protected as outlined in the Family Educational Rights & Privacy Act (FERPA). It is recommended that medication logs be retained in the district according to district archival policy, or if no policy is in place, at least 3 years from the date of the log.

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Medication Incidents

School policies and procedures should include what an individual must do if there is an incident involving medication. A medication incident includes any failure to administer a medication as prescribed for a particular student. Medication errors most often occur when an individual is interrupted or distracted. Eliminating distractions and/or other responsibilities during periods of concentrated medication administration can increase safety and decrease the potential for errors.

Medication errors include but are not limited to:

• Omitting a medication;
• Administering a medication to the wrong student;
• Administering an incorrect dose of medication;
• Administering the wrong medication to the student;
• Administering a medication at the wrong time;
• Administering the medication by the wrong route; and
• Student refusal

Schools should have policies to address handling situations with students who do not appear or refuse to take ordered medications. If a medication is not administered, policies should address the extent to which school personnel will attempt to administer the medication and parent notification procedures. Any medication incident should be:

• documented on according to your school’s incident report process
• reported to the school nurse
• reported to relevant parties

The school nurse should review the report and take necessary steps to avoid problems in the future.

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Storing Medications

Non-expired medications must be kept in the original pharmacy or manufacturer labeled containers. Prescription medications must contain the original pharmacy label including the student’s name, name of the medication, dosage, time for administering, expiration date and name of the medical provider.

Per 6 CCR 1010-6, 6.13, all medications should be inaccessible to children. All medications except emergency medications should be stored in a locked location used exclusively for medications.  Emergency medications should be stored in an unlocked location, inaccessible to children and immediately available to trained school personnel. Medications requiring refrigeration should be stored in a locked refrigerator or in an impervious secondary container in the refrigerator.  Also see Controlled Substances section for storage of these medications.

There may be circumstances (such as licensed child care centers) where a student’s medications must be kept in the classroom. In these situations, care should be taken to ensure that the location is secure and not easily accessible to students. 

Note: Childcare Facility Licensing rules include these additional storage requirements:

• Over-the-counter medication must be kept in the originally labeled container and be labeled with the child's first and last name.
• Controlled medications must be counted and safely secured, and specific policies regarding their handling require special attention in the center's policies. Access to these medications must be limited.
• When away from the classroom, staff assigned to supervise the child must carry the emergency medication.

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Transporting Medications

Medications should be transported to and from school by a responsible family member who delivers the medications to a designated individual in the school. Medications should be delivered in original pharmacy or manufacturer labeled containers. Students who have been approved to carry and self-administer their own medications may transport them to and from school. Controlled substances should not be transported by students.

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Disposing of Medications

Medications should always be sent home with a responsible family member once the order is complete, it is expired, or at the end of the school year. If you must dispose of medications that are not picked up, follow your district policy.  Per the U.S. Food & Drug Administration (FDA) ways to safely dispose of expired or unused medications include: 

Use a drug take back location: DEA-authorized collector in your community

Dispose of by mixing with an unappealing substance such as dirt, cat litter or used coffee grounds.  Put it in a sealed bag and then in the trash. Always maintain the students privacy when doing this.

• FDAs Where & How to dispose of unwanted medications
• Safe Opioid Disposal - Remove the Risk Outreach Toolkit
• Colorado Take Back Program
• CDPHE Preparing medical waste for disposal

Note: Childcare rules specify:  If a medication is out of date or left over, the parent/guardian is responsible for picking up the medication. If the parent(s)/guardian(s) do not respond, the center must dispose of the medications as required by the Colorado Department of Public Health and Environment.

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Self-Administration

Colorado law (C.R.S 22-1-119.3 & C.R.S.22-1-119.5) allows the student to possess and self-administer medication that is prescribed by a licensed health-care practitioner when following district policy. Parents or healthcare providers may request that students be allowed to carry and self-administer their own medications. Individual school districts should have specific policies on self-administration of medications, especially in the case of emergencies.

Before a student is permitted to self-administer medication, the school nurse should facilitate a discussion with the student, healthcare provider, parent and school administrator, which may include these considerations:

• Is the student self-directed and knowledgeable about their condition and medication?
• Does the severity of health condition warrant carrying and self-administration?
• Does the student demonstrate the ability to self-administer medication properly?
• Is there an order in place per district policy (i.e. written authorization from provider and parent)?
• Is the school nurse able to monitor the self-administration process?

A self-carry contract should be signed by the student, parent/guardian, and school nurse per district policy.

Students should be informed that self administration of medication is a privilege granted to them as an individual.  They should be advised that medication can only be possessed and consumed by the student and must not be shared with peers.  If a student is self-administering their medication inappropriately, the ability to self-administer should be restricted per district policy.

Per 1 CCR 301-68, 7.04,  students shall carry only one day's dose of a prescription medication and the medication shall be kept in the original container with the prescription label that includes the student’s name, name of medication, dosage and the name of the prescribing Healthcare Practitioner. This restriction shall not apply to medication that is contained in a multi-dose device including but not limited to asthma inhaler or insulin pump.

It is recommended that additional medication be kept in the health office in the event the student does not have their medication with them.

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Controlled Substances

The following information was confirmed by the Chief Pharmacy Inspector for the State of Colorado. Neither the Pharmacy Board Rules nor the Drug Enforcement Agency (DEA) requirements for controlled substances apply in the school setting. The Pharmacy Board Rules and the DEA requirements are built for and only apply to pharmacies and other dispensation sites and do not apply once a medication is dispensed to a student/child from a pharmacy. For emergency meds that are also controlled substances, as long as the medications are student prescriptions that the school is maintaining (which means the meds belong to the student, not the school), the school can store them unlocked and accessible at all times.

Best practice considerations for managing controlled substance medications at school include the following:

• Controlled medications should be delivered to the school by a responsible family member and not carried by the student.
• Non-emergency controlled medications should be safely secured, locked, and inaccessible to students
• Emergency medications that are also a controlled substance can be stored in a location that is inaccessible to students, immediately available to trained school personnel and in an unlocked location per 6 CCR 1010-6, 6.13 and Chief Pharmacy Inspector for the State of Colorado.
  • The School Nurse, in collaboration with the school administration, should determine where to safely store the medication.
• Controlled substance medications should be counted and documented when received in the health office and according to district protocol.
• The MAT course recommends counting and documenting controlled substance medications when the following occurs:
  • When medication is received
  • When medication is returned to the parent/guardian
  • When medication is administered to the child/student
• The MAT course also recommends counting all controlled substance medications with a witness every two weeks, and documenting how much medication is left.
  • If the count is discrepant with records, theft should be suspected, and local law enforcement should be notified.

PRN Medications

Occasionally a parent/guardian may request that medication be kept at school for specific situations.  PRN is an abbreviation which translates to “as needed”. School nurses should be cautious when asked to delegate medication on an “as needed” basis. As with all medications, there should be parental/guardian written permission (consent) on file as well as orders from an authorizing provider. The prescriber should include specific indications for when this medication should be administered.

Administering delegated PRN medications should not require nursing assessment or judgment by the delegatee. Best practice is that the school nurse is notified when a PRN dose is needed, and the nurse makes the determination after an assessment of the student.

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Over the Counter Medications (OTC)

Over the Counter Medications (OTC)Colorado law C.R.S. 12-255-132 allows over-the-counter medication to be given in K-12 schools by appropriately trained staff (School nurse or delegatee) with a standing order from a physician and written instructions from the parent or guardian. Specific district protocols should be developed as to when and why the medication should be administered.

Depending on district policy, this may include:

• The school stocks OTC medication and obtains a prescriber’s standing order and written parent/guardian permission
• The parent/guardian supplies the OTC medication with a prescriber’s standing order and written parent/guardian permission
• The parent/guardian supplies the OTC medication and a student-specific order and written parent/guardian permission.

Just because OTC preparations can be purchased without a prescription does not mean they are harmless. Many of these OTC products have side effects and can cause adverse reactions.  They may also have interactions with other medications and foods.  Medication should be administered per manufacturer’s recommended instructions, or per student-specific provider’s orders.  School districts, in consultation with their school nurses, should consider whether the benefits of administration of OTC medications outweigh the risks.

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Stock Epinephrine

According to C.R.S 22-1-119.5, schools may adopt a policy to stock epinephrine auto-injectors for use on any student the school nurse or designated personnel believes is experiencing a life-threatening allergic reaction. The Chapter 13 rules on delegation state that the use of stock epinephrine is considered a training and not a delegation. Stocking Non-Specific Epinephrine Auto-injectors In Colorado Schools can provide guidance if your district adopts a policy to stock epinephrine auto-injectors. Of note, schools also have statutory requirements for reporting to CDE numbers of staff who are trained in use of stock epinephrine. In addition, regardless of whether schools maintain a stock supply of epinephrine, if a severe allergic reaction incident occurs at school or a school-related event or if epinephrine is administered, schools must submit a report to CDE within 10 days.

• Reporting form links are located on the CDE School Nursing & Health home page under “Data Reporting”.

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Stock Naloxone

According to C.R.S. 22-1-119.1, schools may adopt a policy to maintain a stock supply of opiate antagonists. Statue states the following must be in place for a school district to possess and administer naloxone:

• A policy must be adopted by the local board of education
  • The policy must include permission to obtain, how the stock opioid antagonist supply will be maintained, and administration of opioid antagonists
• A standing order must be in place
• Training for individuals who wish to administer an opioid antagonist to individuals at risk of experiencing a drug overdose.
  • Training must include risk factors for overdose, recognizing an overdose, calling emergency medical services, rescue breathing, and administering an opiate antagonist.

For more information on stock opioid antagonists please see the CDE School Nurse Training Tools webpage.

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Complementary and Alternative Medicine

Complementary and alternative medicine (CAM) is the term for medical products and practices that are not part of standard medical care. The National Center for Complementary and Integrative Health, (2023) is a government agency that has useful information regarding the use of CAM.  This website includes information including resources, potential side effects and cautions on herbs and botanicals, vitamins and minerals, and probiotics, which are often sold as dietary supplements.

Complementary and alternative medicine is subject to less federal regulation. While there are indications that some may be helpful, more needs to be learned about the effects of these products, especially in children and about their safety and potential interactions with medicines and other natural products.

Home remedies, homeopathic medication, vitamins, and supplements must not be administered to children in childcare. 12 CCR 2509-8

District policies for CAM should require:

• A written order from an authorized health care provider and it should include the condition for which the product is being used;
• A written permission (consent) from the parent/guardian to administer the remedy;
• Verification that the product and requested dosage are safe for the student (considering age, body weight, and condition), and
• Reasonable information about therapeutic and untoward effects and interactions.

For further guidance see The National Association of School Nurses (2021) Medication Administration Clinical Practice Guidelines in the School and the NASN Position Statement on Complementary and Integrative Therapies (NASN 2022). 

The school nurse should consider the following when determining whether to administer alternative medication in the schools:

• The approved Colorado Medication Administration course does not include homeopathic or herbal preparations as a routine medication so unlicensed staff have not had training specific to these products.
• Dosage requirements are unlikely to exist for the administration of these types of preparations to children.
• More research is needed to demonstrate the safety and efficacy of these substances in children.
• The school nurse should contact the prescribing provider to clarify the desired outcome of the therapy, how long the student has been receiving this therapy, the importance of administering this alternative therapy during the school day, safety concerns for this therapy, and possible interactions with other medications the student is currently receiving.
• The school nurse should determine if the medication is United States Pharmacopoeia (USP) verified or National Sanitation Foundation (NSF) certified. USP-verified and NSF-certified products have been evaluated to ensure their quality. This ensures the label is accurate in terms of potency, the product does not contain contaminants and good manufacturing practices were used.

One of these badges should be found on the product label: USP Logo or NSF Logo

If the school nurse is able to comply with criteria from the Nurse Practice Act, then these medications may be delegated on a case-by-case basis.

The use of essential oils and diffusers have become popular for a variety of ailments. The oils can be used in a variety of ways and include diffusing them into the air by using a vaporizer or rubbing them on the skin. It is important to consider the effect the essential oils and perfumes have on other children and staff who may be sensitive to the smell including triggering asthma or other respiratory symptoms. While the Colorado Board of Health rules do not prohibit the use of essential oils and diffusers in the K- 12 setting, they are not permitted in childcare facilities which includes preschools and after school care (6 CCR 1010-7).

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Experimental Medications

It is recommended that a parent's request to administer experimental medications at school should be evaluated on a case-by-case basis with the parent, the prescribing healthcare provider, and the school nurse to assure the nurse has information needed to administer safely.

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Clinical Trial Medications

The request to administer medication at school should be accompanied by:

• A copy of the written protocol or student summary from the research organization;
• A copy of the detailed consent form signed by the parent/guardian that describes the study (including the potential benefits and risks);
• The signs and symptoms of adverse reactions to be reported;
• The name and telephone numbers of the investigators or research team;
• Written and signed orders from the prescriber; and
• Written permission (consent) from the parent/guardian to administer the medication.

If these criteria can be fulfilled, the medication may be administered by a registered nurse or delegated on a case-by-case basis.

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Off-Label Use of Medications

Off-label use of medications refers to those drugs used for a purpose other than that identified by the manufacturer or approved use by the Federal Drug Administration (FDA). Parents or healthcare providers should provide the school nurse with adequate information to support the safe administration at school, such as:

• Published anecdotal reports of use in children for the specific condition for which the medication is being prescribed
• Manufacturer reports or reports from a reliable pharmacy
• Current medical journals
• Information from a pediatric medical or mental health facility
• Consent form signed by the parent or guardian and written signed orders from an authorized prescriber

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Topical Medications

Topical medications include eye drops and ointments, ear drops, and skin creams, ointments, and medication patches that provide continuous release of medication through the skin. When applying any topical medication, you should wear gloves and dispose of them after use.

In the K-12 setting, topical preparations applied for preventative purposes, such as sunscreen, do not require an order unless specified in district policy but a written authorization from the parent is still recommended. However, if the topical preparation is being used to treat a medical condition, broken skin, or open wound, then an order from a prescribing healthcare provider and written authorization from the parent would be required.  For example, if a child has an acute diaper rash requiring ointment, an order would be necessary. 

Note:  Childcare rules specify:  Topical preparations such as petroleum jelly, diaper rash ointments, sunscreen, insect repellent, and other ointments may be administered to children with written authorization from the parent(s)/guardian(s). These preparations may not be applied to open wounds or broken skin unless there is a written order by the prescribing health care provider.  For details of sun protection and sunscreen, see the childcare rules 12 CCR 2059-8, 7.702.51 C.

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Medical Marijuana

C.R.S. 22-1-119.3 requires Colorado schools to adopt and implement a policy for student possession and self-administration of medications prescribed by licensed health practitioners. The bill also requires that such a policy include processes for the storage, possession and administration of medical marijuana in a non-smokeable form to a student who holds a valid recommendation from a licensed physician.  See the CDE Fact Sheet Concerning Administration of Medical Marijuana at School for more information.  For CBD and Hemp administration, see above section on Complementary and Alternative Medications.

Note: Per 12 CCR 2059-8, 7.702.105 Child Care Programs and Preschools Operated by a Public School District, the administration of medical marijuana must comply with policies listed in Sections §12-255-120, 12-255-127, and 2-30-116. C.R.S.

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Out of State Orders

The Colorado Medical Practice Act governs the prescribing of medication. Section 12-240-107 of the Colorado Medical Practice Act does allow occasional rendering of services in this state by a physician if the physician: 

• Is licensed and lawfully practicing medicine in another state or territory of the United States without restrictions or conditions on the physician’s license;
• Does not have any established or regularly used medical staff membership or clinical privileges in this state;
• Is not party to any contract, agreement, or understanding to provide services in this state on a regular or routine basis; 
• Does not maintain an office or other place for the rendering of such services; 
• Has medical liability insurance coverage in the amounts required pursuant to section 13-64-302 for the services rendered in this state; and
• Limits the services provided in this state to an occasional case or consultation.

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Field Trips and School Sponsored Events

A student may not be prevented from participating in a school sponsored event, such as a field trip, solely based on a special health need such as the administration of a medication.  The student’s right to access the educational setting, including school sponsored events, is protected by federal law.

The school nurse should establish procedures to handle administration of medications when students go on field trips or participate in other school sponsored events. The school nurse should prepare the medication themselves and not delegate this task. If that responsibility must be delegated, the school nurse should include training in the preparation of field trip medications in the delegation training of the responsible school staff member. Medical marijuana cannot be taken on field trips or school sponsored events.

Although it is recommended that K-12 staff members who administer medications on field trips have the Medication Administration Training (MAT), it is recognized this may not be possible. If necessary, staff members who participate in these activities may be provided with a student-specific delegation and a one-time responsibility to administer medication(s) that ends when the field trip is over.

See more considerations for field trips on the CDE School Nurse Training Tools page.

A child may not be prevented from participating in a school-related activity, such as a field trip, solely on the basis of a special health need. For students who are not self-administering, the school has several options:

• The School Nurse can attend the field trip
• Staff who have been delegated to can attend the activity and administer the medication
• Staff who will participate in the activity can be provided with the one-time delegation to carry and administer the medication
• The parent/guardian may be invited to attend the activity and administer the medication, but this cannot be a requirement in order that their child may participate in the activity
• The student’s healthcare provider can be consulted and may order the medication time to be adjusted or the dose eliminated for that day.

If the school-sponsored trip takes place in a different state or country, there will be licensing laws that need to be considered so the school nurse can legally provide nursing services. The Nurse Licensure Compact (NLC) allows nurses to have one multistate license with the ability to practice in both their home state and other compact states. Some states do not have a compact law. The school nurse must practice according to the laws in the state that care is being provided. For trips occurring out of the United States, the nurse or a school representative should contact the U.S. State Department, which will direct the inquiry to the appropriate international contact (Erwin et al., 2014).

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References

• Colorado Department of Education, (n.d.-1) Special education rules and regulations.  Retrieved on July 31, 2023 at https://www.cde.state.co.us/spedlaw/rules
• Colorado Department of Education. (2022) Colorado State Board of Education. Rules for the administration of the exceptional children’s education act. CCR 301-8. https://www.coloradosos.gov/CCR/GenerateRulePdf.do?ruleVersionId=10194&fileName=1%20CCR%20301-8 
• Erwin, K., Clark, S., & Mercer, S.E. (2014).  Providing health services for children with special health care needs on out-of-state field trips. NASN School Nurse, 29(2), 85-88
• Healthy Child Care Colorado. (n.d.). Child care health consultation. Retrieved on August 1, 2023 at https://healthychildcareco.org/programs/child-care-health-consultation/  
• National Association of School Nurses. (2021). Medication Administration Clinical Practice Guidelines in the School. Author.
• National Association of School Nurses. (2022). Complementary and integrative therapies [Position Statement]. Author.
• National Survey of Children’s Health. Child and Family Health Measures (2022). Retrieved on July 31, 2023 from https://www.childhealthdata.org/browse/survey/results?q=9254&r=1&g=1002
• Resha, C, Taliaferro, V, eds. Legal Resources for School Health Services. Nashville, TN: SchoolNurse.com: 2017

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Resources

• A Training for Unlicensed Assistive Personnel in Public, Charter, Private and Parochial Schools, Child Care Centers, Preschools, School-Age Child Care, Residential Camps, Day Camps, and Family Child Care Homes, 2017, Sixth Edition.
  • School Staff: www.co.train.org  
  • Child Care Staff: https://www.coloradoshinespdis.com
  • Training materials and forms can be accessed at Healthy Child Care Colorado at  https://healthychildcareco.org
  • You must apply to join the CCHC Center to access this site.
• Individuals with Disability Education Act (IDEA). (2004). 20 U.S.C.1412 (a) (12) and (e) 34 C.F.R. 300.154. U.S. Government Printing Office (GPO) Electronic Code of Federal Regulations (e-CFR). Retrieved on 08/02/2023 from https://www.ecfr.gov/current/title-34/subtitle-B/chapter-III/part-300 
• National Center for Complementary and Integrative Health (2023). Website accessed at https://www.nccih.nih.gov/health/complementary-alternative-or-integrative-health-whats-in-a-name on 07/31/23.
• U. S. Department of Education, Office for Civil Rights. (2017). Sub-part D of the Section 504, preschool, elementary, and secondary education. 104.31 application of this subpart. https://www2.ed.gov/policy/rights/reg/ocr/edlite-34cfr104.html
• Resha, C, Taliaferro, V, eds. Legal Resources for School Health Services. Nashville, TN: SchoolNurse.com: 2017

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Statutes and Rules Governing Medication Administration in School & Child Care Settings as of 2024

Statute:  Colorado Revised Statutes (CRS)	Rules: Code of Colorado Regulations (CCR)
Title 22. Education 22-1-119. Students - dispensing of drugs to - liability 22-1-119.1. Policy for employee and agent possession and administration of opiate antagonists - definitions. 22-1-119.3. Policy for student possession and administration of prescription medication - rules - definitions. 22-1-119.5. Asthma, food allergy, and anaphylaxis health management - self-administered medication - staff-administered medication - rules - definitions.	1 CCR 301-68 Rules For Administration Of Medications (Department of Education) 1.00 Definitions 2.00 Policy for Management of Food Allergy and Anaphylaxis in the School for Students with a Known Allergy 3.00 Appropriate Staff Training 4.00 Requirements for Students to Self-Carry Asthma/Anaphylaxis Medication 5.00 Use of Stock Epinephrine Auto-injectors in Emergency Situations in School Settings 6.00 Reporting Requirements 7.00 Policy for Management of Student Possession and Administration of Prescription Medication 8.00 Requirements for the Administration of Medical Marijuana by School Personnel
22-1-132. Seizure safe schools	1 CCR 301-113 Rules for Individualized Medical Seizure Action Plans (Department of Education)
Title 12. Professions and Occupations Nurse and Nurse Aide Practice Act:  Title 12, Article 255 12-255-131. Delegation of nursing tasks - rules 12-255-132. School nurses - over-the-counter medication	3 CCR 716-1 Nursing Rules And Regulations (DORA - State Board Of Nursing) 1.13 Rules And Regulations Regarding The Delegation Of Nursing Tasks “Chapter 13 Delegation Rules” 1.13. F. Delegation Of The Administration Of Medications In Schools And Licensed Child Care Facilities 1.13. G. Delegation Of Insulin And Glucagon Administration In The School Setting, Licensed Child Care Facility Or Ddn Setting 1.13 H. Exclusions from the Rule 1.13 (included child care provider section) 6 CCR 1010-6 Rules and Regulations Governing Schools in the State of Colorado (Dept. of Public Health & Environment) 6.13 Health Services
12-280-103.  Pharmacists, Pharmacy Businesses, and Pharmaceuticals - Definitions - rules	3 CCR 716-1  “Medication” means any prescription or nonprescription drug as defined in section 12-280-103, C.R.S
12-240-107.  Medical Practice. Practice of medicine defined	4 CCR 749-1  Naturopathic Doctors Rules and Regulations
Child Care Licensing Act, Sections 26-6-101 to 26-6-119, C.R.S.	12 CCR 2509-8 Child Care Facility Licensing (Department of Human Services) 7.702.41 General Requirements for All Staff 7.702.105 Child Care Programs and Preschools Operated by a Public School District
Title 25. Public Health and Environment  25-1.5-101(1)(a) and (h), 25-1.5-102(1)(a) and (d), 25-1-108(1)(c)(I) and 25-5-508, C.R.S.	6 CCR 1010-7 Sanitation of Child Care Facilities of Colorado (Department of Public Health and Environment) 6-201 Staff handwashing 6-202 Handwashing by toddlers and older children 6-301 Medications and First Aid

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These guidelines were developed by the Colorado Department of Education School Health Services Office with contributions from Healthy Child Care Colorado and Colorado school nurse leaders.  Updates occur as needed to reflect current statues, rules and regulations or to clarify content.

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