NYONE Position Statement: HHA Administration of Medications, MRT Recommendation # 1



Position Statement

HHA Administration of Medications

MRT Recommendation # 1

The New York Organization of Nurse Executives (NYONE), the organization that speaks for nursing executives/administrators/managers in multiple settings, strongly recommends the inclusion of the following criteria in any bill/regulation relating to the delegation of medication delivery to home health aides:


Currently, tasks permissible under special circumstances may only be performed for a patient whose characteristics and case situation meet all of the following criteria:


  • The patient is self-directing. A self-directing patient is defined as one who has the capability to make choices about activities of daily living, understands the impact of these choices and assumes responsibility for the results of the choices.
  • The patient has a need for assistance with the task or activity for routine

 maintenance of his/her health.

  • The patient cannot physically perform the task or activity because of his/her disability.
  • The patient has no informal caregiver available at the time the task or activity must be performed or the caregiver is available but is unwilling or unable to perform the task or the caregiver's involvement in unacceptable to the patient.


The MRT regulation would expand this delegation to home health aides for a more vulnerable population and therefore additional stipulations are recommended. In the situation of a NON-SELF DIRECTING PATIENT, the following rationales are provided:



  • Tasks which are permissible under special circumstances are not routinely taught in a home health aide training programs. Since these tasks are complex, each home health aide must receive training in the exact skill and/or procedure to be performed with each patient.


  • Training and competency evaluation in the performance of these tasks are not transferable from patient to patient. Additionally, a limited number of tasks have specific criteria that must be met in order to assign an aide to the performance of the task for a patient.



THE MINIMUM additional stipulations are recommended as follows:


  1. an RN makes a determination about each case as appropriate to the uniqueness of the patient
  2. the HHA received special training from class and from a registered professional nurse on each visit about the patients medications and medical circumstances,
  3. the HHA demonstrates ongoing competency following the training
  4. a documented family/friend willing to assist in the oversight
  5. nursing visits by an RN be increased to sustain review of HHA continued competency
  6. HHA communication to RN about changes in patient’s status must be  required
  7. there is a specific and appropriate time interval established between RN assessments as to the safety of pre-pouring of medication per individual patient need.
  8. a standard curriculum for HHA educational requirements be set with additional training to include:
    1. chronic diseases
    2. infection control standards related to medication administration
    3. enhanced  verbal and written communication skills 
  9.  medications that require alternating or changeable strengths based on another variable such as anticoagulation be more restricted as dictated by the patient’s situation/condition.


In order to ensure the safe and effective implementation of the MRT recommendation related to RN oversight of medication delivery by HHAs, NYONE recommends that any legislative/executive mandate or regulation clearly delineate the above referenced criteria.




NYONE Position Delegation to HHA of Medication Delivery 6

Adopted 2 14