Q: Can parents/guardians change their child’s medication orders written by their provider?
A: No. Changes in medication regimes must be ordered by a healthcare provider. A parent/guardian cannot direct licensed health professionals to administer medications to their child that are inconsistent with healthcare provider’s order.

Q: Is parent/guardian consent needed for a private healthcare provider to clarify an order they have provided to the school?
A: No. Parent/guardian consent to speak with the private provider is not required for the health care provider to clarify orders per the Health Insurance and Accountability and Portability Act (HIPAA).

Q: Does the HIPAA Privacy Rule allow a healthcare provider to disclose Protected Health Information (PHI) about a student to a school nurse or physician?
A: Yes. The HIPAA Privacy Rule allows covered healthcare providers to disclose PHI about students to school nurses, physicians, or other healthcare providers for treatment purposes without the authorization of the student or student’s parents/guardians. For example, a student’s primary care physician may discuss the student’s medication orders with a school nurse, who will administer the student’s medication.

Q: What should be documented in the student’s cumulative record?
A: Pursuant to Rules of the Board of Regents, Part 29 § 29.2(3), licensed health professionals must maintain a record for each patient which accurately reflects the evaluation and treatment of the patient. Additionally, unlicensed personnel assisting Supervised or Independent Students to take their own medication should document the medication was taken by the student.

Q: What is the best practice for health records documentation?
A: Best practice for documentation in health records includes but is not limited to:

• Retain the written order from the prescriber.
• Retain the parent/guardian consent.
• Document pertinent information about medication, and other vital signs, blood glucose etc. related to the administration in the Cumulative Health Record (CHR).
• Maintain an individual daily Medication Administration Record (MAR) for each student administered or who self-administered medication in the health office.
• Periodically and as needed, evaluate and summarize student response to medication, including assessing for effectiveness and side effects.
• Periodically summarize daily medication records in the CHR.

Q: What information must be included in a Medication Administration Record (MAR)?
A: The MAR must contain the following information:

• Student name and date of birth
• Medication name, dosage, route, and parameters
• Date and time administered
• Documentation of any missed dose or student refusal
• Signature and title of the health professional administering. Unlicensed school personnel who assist students in taking their own medication should also sign the MAR to document the student took their medication. Note - If initials are used to sign the MAR, a separate log of all individuals' signatures (with title if applicable) and their initials must be kept for all personnel signing any student’s MAR.
• Documentation of parameters required for administration (e.g., vital signs, carb count, blood glucose, etc.).

Q: May a school nurse follow a medication order written by a provider from out of state?
A: In accordance with New York State statute, full licensure and current registration are required of any professional who practices in New York State. Pursuant to Education Law §6526, the only out of state practitioners that may prescribe medically necessary care/treatment, are physicians licensed in a bordering state and who reside near the border of this state. The border vicinity is usually defined as less than 25 miles.

Q: What non-patient-specific orders may the school nurse (RN) follow?
A: Education Law Articles 131 and 139 permit a physician or nurse practitioner (NP) to write non-patient specific orders for an RN to follow for:

1. administrating immunizations
2. the emergency treatment of anaphylaxis
3. administering Tuberculosis (TB) Tests
4. administering tests to determine the presence of the human immunodeficiency virus
5. administering tests to determine the presence of the hepatitis C virus
6. the urgent or emergency treatment of opioid-related overdose or suspected opioid-related overdose
7. screening of persons at increased risk for syphilis, gonorrhea and chlamydia
8. administering tests to determine the presence of COVID-19 or its antibodies or influenza virus.

Education Law §6909 states an RN may execute the above non-patient-specific regimen prescribed or ordered by a licensed physician or NP, pursuant to regulations promulgated by the commissioner. 

Q: Who should administer medications in school?
A: Medications must be administered by an appropriately licensed health professional: physicians, nurse practitioners (NP), physician assistants (PA), registered professional nurses (RN), and licensed practical nurses (LPN) under the direction of an RN or the other health professionals listed above. Supervised and Independent Students may be assisted by trained unlicensed personnel to take their own medications. Documentation of the medication dose must be recorded in the individual student’s cumulative health record (CHR) and/or MAR.

Q: Can a certified Athletic Trainer (ATc) administer medication in a school setting?
A: No.

Q: If a student’s medication is expired, can the school nurse administer that medication?
A: No, a licensed health professional should not administer expired medications. The parent/guardian should be notified of the need to bring in new medication to replace the expired one at least one month before expiration. Note: Pharmacists in NYS are not required to place expiration dates on labels, with a few exceptions, such as antibiotic suspensions. Therefore, manufacturer expiration dates may be relied upon per the NYS Board of Pharmacy (The date on the pharmacy bottle is one year from the date the prescription was filled.)

Q: Where should medications be administered?
A: Students will generally need to go to the health office for an appropriately licensed health professional to administer the medication to the student or to take their own medication. Education Law Article 19 §916, §916-a, §916-b requires that schools permit students with written provider orders, provider attestation, and parent/ guardian consent to carry and self-administer: inhaled rescue medications, epinephrine auto-injector, and insulin, glucagon, and other supplies for diabetes management. These students must not be made to come to the health office for their medication.

Q: When should medications be administered?
A: All medications should be administered as close to the prescribed time as possible. Given student schedules and students’ compliance with coming to the health office in a timely fashion, medications accepted for school administration generally may be given up to one hour before and no later than one hour after the prescribed time, which is considered best practice.

Q: If a tablet does not come in the dose the provider ordered, may it be split using a pill cutter?
A: On occasion, a tablet does not come in the dose the provider ordered. If the medication tablets are scored, they may be split with a pill cutter.  Using a pill cutter is necessary to ensure the pill splits evenly and does not crumble. Such scored tablets may be cut by a nurse prior to administration.  Alternatively, the parent/guardian may request they are cut by the pharmacist. Tablets that are not scored should not be cut since they will not split evenly and the dosage will be unknown.
 
Q: What happens if a parent/guardian withdraws their written consent for the school to administer a particular medication?
A: The school will need to comply with the parent/guardian instructions and contact the provider to inform them and obtain a written order to discontinue the administration of the medication at school. Parent/guardian making verbal requests to withdraw consent should be instructed to do so in writing. School protocols may permit acceptance of verbal parent/guardian requests if followed up by written requests within a specific time frame.

Q: How is a medication error defined?
A: A medication error includes any failure to administer medication as prescribed for a particular student. Medication errors include wrong recipient, wrong medication, wrong dose, wrong route, wrong time, wrong frequency, wrong assessment, and wrong documentation. 

Q: How should medication errors be addressed?
A: Medication errors should be addressed immediately in accordance with the school’s medication management protocols. The school nurse (RN) should assess the student and, if appropriate, contact the Poison Control Center (if the wrong medication or an overdose is given) and/or 911 per school policy. If a school nurse is not present to assess the student, the medical director should be immediately consulted for direction. If they are unavailable, the parent/guardian should be notified to pick up their child for follow-up care or, if deemed necessary, informed that the student is being transported for follow-up emergency care. 

Q: What steps should be followed if a medication error occurs?
A: The following steps should be taken for medication errors:

1. Notify the licensed prescriber as soon as possible, particularly if wrong dose or medication was administered;
2. Notify supervisor and/or school administrator and school medical director;
3. Notify the parent/guardian; and
4. Complete a written report of the medication error detailing: student's name, specific statement of the medication error, results of the school nurse assessment, who was notified, and what remedial action was taken.

Pursuant to Rules of the Board of Regents, §29.2(3), licensed health professionals must maintain a record for each patient which accurately reflects the evaluation and treatment of the patient. Documentation should include the date and time the medication is administered to or taken by the student, any communication with the healthcare provider and parent/guardian, any special circumstances related to the administration, and notable student reactions/responses to the medication. The documentation must be signed by the writer. 

School nursing personnel and the medical director should review reports of medication errors and take necessary steps to adjust protocols to lessen the likelihood of a future medication error.

Q: Must a school honor a request for the administration of Non-FDA Sanctioned Medication/Supplements during the school day?
A: Requests or orders for use of non-FDA sanctioned medicines including but not limited to, herbal remedies, essential oils, dietary supplements, naturopathic or holistic medicines, and natural products, do not need to be honored by a school district or school nurse. Nurses cannot be required to administer non-FDA sanctioned medicines. When a school does not permit the administration of off-label products, they should explain to the healthcare provider and the parent/guardian that such medications should be administered outside of school. An appropriate notation should be made in the student’s cumulative health record documenting the communication.

Q: What 3 options exist for schools wanting to incorporate Opioid Antagonists (i.e. Naloxone) in their school policy?
A: There are three options available for schools that choose to maintain and administer an opioid antagonist in the school setting. Options to obtain, store and use naloxone in schools are below:

1. School/School District Registers with the New York State Department of Health (NYSDOH) to Become A Registered Opioid Overdose Prevention Program; a school medical director is required.
2. School Nurse Administration of Opioid Overdose Treatments Pursuant to a Non-patient Specific Order and Protocols (Available to licensed medical professionals: physicians & nurses).
3. Participating with a NYSDOH Registered Opioid Overdose Prevention Program Operated by another Organization.

Q: Do OTC medications require both parent and provider written permission to administer at school?
A: Yes, all medications, both prescription and non-prescription, require provider order and parent written permission. See the exception question and answer below.

Q: Are there any exceptions for written provider orders for over-the-counter medication? 
A: There are three exceptions listed below:

1. Sunscreen - the student or an adult staff member, if directed by the student, can apply sunscreen with parent/guardian written consent. Students who cannot self-apply or direct an adult to do so will require sunscreen to be administered (applied) by a licensed health professional only and will require both a healthcare provider order and written parent/guardian consent. 
2. Alcohol Based Hand Sanitizer - may be used with permission from school medical director
3. Personal Use of Insect Repellent - Personal use insect repellent is not a medication (it is a pesticide). Therefore, a healthcare provider order is not required. If the student needs insect repellent applied at school, parent/guardian written consent is required.  Aerosol insect repellent is strongly recommended to NOT be used in schools.

Q: What happens if the provider order is for one brand of either prescription or non-prescription medication, but the parent/guardian brings in a different brand? Is it acceptable for the nurse to administer it?
A: If both brands are identical dosages (i.e. Advil/Motrin - both ibuprofen or Epi-Pen/Auvi Q both epinephrine), the nurse can accept and administer the medication.

Page Updated 5/9/25

Q: Can an RN take a verbal order from a licensed healthcare provider?
A: Nothing in state regulations or statutes pertains specifically to school nurses in relation to verbal orders. As with any RN, school nurses may take a verbal order. We suggest the following procedure, but each medical director sets their own policy. The nurse should repeat the order to the provider for accuracy, have a second nurse verify by listening in (if possible), and obtain the provider's signature on the written order within 48 hours.

Q: May the nurse re-label a medication bottle if there is a change in the dose, time, or frequency of the medication requested in writing by the provider and parent/guardian?
A: When the dose, time, or frequency of medication is changed by a written provider order along with written parent/guardian consent, and the pharmacy bottle label does not reflect the new order, the nurse may label the bottle with the date, new dose, and/or frequency until a new pharmacy labeled prescription bottle is received. This is only permissible if the medication in the existing bottle can be used for the new order.

Q: What extra precautions should be taken upon receipt of controlled substances?
A: Standards of best practice include counting and signing a receipt of controlled substance medication upon receiving the medication from the parent/guardian or another adult. For counting at regular intervals (e.g., daily or once/week) throughout the school year, a count of a controlled substance should be witnessed and documented by another nurse, principal, or staff member designated by the principal.

Q: May schools choose to purchase and stock over-the-counter (OTC) medications for use by students and staff?
A: This practice is not recommended, but it is not prohibited by law. Schools choosing to stock medications must have written patient-specific orders from the student’s provider and written parent/guardian consent permitting the administration of stock medication. Stock medications for staff use should be kept in a location other than the health office for staff to obtain if the school employs licensed health professionals. This is strongly recommended to eliminate any liability for the licensed health professional.

Q: May schools stock albuterol for use by students?
A: Yes, if there is a patient-specific order from their provider and written parent/guardian consent for albuterol, that also authorizes the use of the school’s stock albuterol.

Q: May schools stock Potassium Iodide (KI)?
A: School building administrators located in the ten-mile emergency planning zones of nuclear power plants have been asked to participate in the Potassium Iodide (KI) Program.

Q: What are the 3 functional categories of students when it comes to medication administration?
A: The following are the 3 student functional categories:

1. Nurse Dependent Students (formerly non-self-directed)
2. Supervised Students (formerly self-directed)
3. Independent Students (formerly self-administer and/or self-carry)

Q: What does Nurse Dependent Student mean?
A: Students who cannot self-administer their own medication and cannot be considered in need of supervision are dependent on another person administering the medication to them. Nurse Dependent Students must have their medication administered to them by an appropriately licensed health professional.

Q: What does Supervised mean and who determines the Supervised Student?
A: Students can be determined to need supervision either by the school nurse or the student's provider. Whether a student should be considered a Supervised Student should be based on the student’s cognitive and/or emotional development rather than age or grade. A student may be considered a Supervised Student only if they are consistently able to do all of the following:

• Administer the medication to themself via the correct route
• Identify the correct medication (e.g., color, shape)
• Identify the purpose of the medication (e.g., improves attention)
• Identify the correct dosage is handed to them if they cannot pour own medication for dexterity issue (e.g., one tablet, 2 puffs, 3 units, etc.)
• Identify the time the medication is needed during the school day (e.g., lunch time, before/after recess, etc.)
• Know the parameters or condition(s) under which the medication is to be taken, and will refuse to take the medication if the parameters or condition(s) are not met (e.g., blood glucose or vital sign ranges that are acceptable to take medication, or taken only for headache, shortness of breath, etc.)
• Describe what will happen if medication is not taken (e.g., unable to complete schoolwork, blood glucose will elevate, etc.)
• Refuse to take the medication if the student has any concerns about its appropriateness. 

Q: What does Independent mean and who determines the Independent Student?
A: An Independent Student can self-administer their own medications without any assistance. This status is determined by the healthcare provider ordering the medication and would require a medication order, provider attestation, and parent/guardian permission. The school nurse would not assess those students’ ability to be Independent or instruct them in self-administration. It is recommended that they are instructed on how to safely carry it on their person or store it in a locker. Also have an emergency care plan and additional doses of medication in the health office for use as needed by the student.

Q: Do students who require rescue medications for respiratory conditions, life-threatening allergies, or diabetes have to be permitted to self-carry and self-administer their medications if they have written permissions in place?
A: Students who require medications for respiratory rescue, allergies, or diabetes must be permitted to self-carry and self-administer their medications if they have a healthcare provider order authorizing them to self-carry and self-administer their medications and written parent/guardian consent pursuant to Education Law § 916, 916-a, and 916-b. The healthcare provider’s medication order must attest that the healthcare provider has determined the student is able to self-administer their own medication effectively. 

Q: What about other medications which require timely administration?
A: Independent Students with health conditions warranting rapid administration of their medications should also be permitted to self-carry and self-administer their medication to prevent negative health outcomes if they provide the same documentation as described above. Any questions regarding such orders should warrant a telephone call by the school nurse or medical director to confirm the need for rapid administration, warranting the student to carry the medication.

Q: When must a provider order be renewed?
A: The order, which is valid for 12 months, should be renewed annually or when there is a change in the order. District policy should state whether new provider orders and parent/guardian consent is required at the start of the school year or when the order expires.

Q: Who is responsible for transporting medications to school?
A: The parent/guardian is responsible to have the medication delivered directly to the school in a properly labeled original container by an adult. In limited circumstances, a student who is not able to self-administer their medication may need to carry the medication on the bus in order to transport it to and from school for medical reasons or due to the family’s financial constraints. A written plan to ensure the safety of the student, as well as the safe transport of the medication, should be developed in collaboration with the medical director or school nurse and the parent/guardian.