Non-licensed personell giving medications

[kitkat_12]

HI! I am a new CSN this year coming from years at the hospital. So far it has been overwhelming in the beginning, but things are now starting to settle down as I become more familiar with the job duties. I have a question for other PA Csn's out there. I am responsible for one large public elementary school which I am there for 3 1/2 days during the week and have an health aide that covers me there on the other 1 1/2 days. I also oversee two smaller private schools, one which I am at 1 day/wk and the other I am at 1/2 day/wk. The one private school has no other licensed nurses there the other 4 1/2 days (secretary covers any meds/first aid) and the other private school has no licensed personell there 2-3 of the days during the week (that secretary also handles meds and first aid). That's how they've been doing it for years. I did find that in PA we are not allowed to delegate "the nursing function of med administration to the principal, teacher, or administrative personell" (..pa dept of heatlh med admin guidelines 6/21/10)- so that would prevent me from 'delegating the task of administering the meds' (which are only a few) to the private school secretaries during my absence. It also cites in there that the according to CSPG No 101 and No 95 that the principal is qualified to perform "supervision and direction of certified and non-certified staff persons required for school operation exclusive of directing health services controlled by the Nurse Practice Act". So I take it that means the principal also cannot delegate the task of med administration to the secretaries. My question, I guess, would be does that apply also in the private (catholic) school sector, also? We do have some type of licensed nurse coverage at all of our public schools (5), but are smaller catholic schools (4) which we oversee have limited to no coverage. Since I do have a few routine meds at my two schools, should there be a nurse there just to give those meds out? Also according to doh regs at 28 Pa Code 23.51 states that "a child in private, parochial, and public schools shall be provided with school nurse services in the school which the child attends"- so does med admin fall under school nurse serices? I guess my mind is now just running on tangents, I'm used of crossing all my t's and dotting all my i's, and want to be sure I am CYA. Any thoughts, suggestions, or other experience in similar situations appreciated?