Dear CNO
My work has hired personal support workers (PSWs) to help the nurses on our unit with our busy morning tasks. Can these individuals help administer medication to clients? Am I accountable if the PSW makes a medication error?
Context matters so much when it comes to health care decisions, and this is a wonderful example. Let’s unpack the different aspects you should consider.
Consider the setting and workplace policies
Personal support workers are unregulated care providers (UCPs) and are not accountable to CNO, but to the employer. Reaching out to your employer to determine the scope, responsibilities and requirements of UCPs can help you understand their role in providing safe client care. Depending on your practice setting, there may also be specific legislation that describes the role of UCPs, which also should be considered.
Consider the client’s situation and condition
Client safety is of utmost importance. The client’s situation and condition should be considered in determining whether it is appropriate for the UCP to administer medication. For example, is the client’s condition well-controlled and their response to the medication predictable? Additionally, consider whether there are environmental supports in place, such as policies and procedures, and other care providers available for consultation or intervention. For more information on making decisions about activities performed by UCPs, see the decision tree on page 8 of the Working with Unregulated Care Providers practice guideline.
Consider whether the medication practice involves a controlled act
For instance, the administration of oral medications is not a controlled act. That means you can teach, assign, or supervise a UCP to administer oral medications, provided they meet a few conditions:
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administration of oral medications by UCPs is supported by employer policies and practice-specific legislation (for example, Fixing Long-Term Care Homes Act, 2021)
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you teach, assign or supervise according to expectations outlined in Working with Unregulated Care Providers practice guideline
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the UCP has the competence to perform the activity
If the medication administration involves a controlled act procedure, then this comes with a special set of considerations. Let’s say a client needed sliding-scale insulin to be administered subcutaneously as part of their care plan. This would be considered a controlled act because you are administering a substance by injection. Unregulated care providers do not have the legal authority to perform controlled acts unless it is specifically delegated to them. Delegation is the formal process where a regulated health care provider, who has the authority and competence to perform a controlled act, transfers that authority to someone who otherwise would not have the authority to perform it.
There are specific requirements that must be met before a controlled act can be delegated to a UCP, including ensuring that the UCP has the competence to perform the controlled act safely. You can read about the requirements of delegation in the Scope of Practice standard. Before delegating the controlled act, you may want to teach the UCP and then directly supervise them performing the activity safely and competently. Collaboration and clear, professional communication between nurses and UCPs are vital within the health care team, as outlined in Principle 4 of the Code of Conduct. It ensures a shared understanding of roles and responsibilities in delivering safe client care.
Addressing concerns regarding UCP performance
Unregulated care providers do not work under another health care professional's registration. As nurses, you are responsible for your own actions and their consequences, but you are not accountable for the decisions or actions of other care providers, including UCPs. If you are concerned about a UCP’s knowledge, skill or judgement to perform a certain task, you must work with the UCP and notify your manager and employer that the UCP reports to.
Thanks for writing,
Dina Vaidyaraj, RN, BScN, MN
Further Reading
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