I think a facility that I once worked in would be in possible trouble also (this has been several years ago so the facility may have mended its ways by now and I don't know the exact laws in that state anyway...).
The LPN in charge had the residents' meds in labeled packets for day and time, with each residents' meds in their own drawer, and the PRNs written what they were PRN for and how often they could be taken, etc., in the MAR, along with the regular meds. The LPN gave the meds during the day on weekdays (7-4, I think, or thereabouts).
At all times when the LPN was not there, the CNAs and myself and a few others who like me were completely uncertified, labeled RAs (resident assistants), would be responsible for giving out the meds including PRNs and narcotics, and signing off in the MAR. Since I usually worked the evening shift this meant suppertime and bedtime meds. As well as give eyedrops and ointments and even a couple suppositories once or twice. No injections, though.
I do not know who would be legally responsible in this case if a wrong med were given or if a med were forgotten. It is also kind of a different situation because we did not have to find and count all the meds for the patient, except to measure some liquids; they were already in the packet.
At that time I was an ignorant high school student, and did not realize the implications of this, just thought it was the usual way until I arrived at nursing school and we were taught all the serious implications of passing meds! I did know a lot more about a MAR when we started that segment of class than a lot of the other students, but I do not know if that was a good thing or not! I would cringe in horror now to have that system of passing meds in a facility where I worked!!
Wow, sorry, I got kind of long-winded here...