Discussion
Regions may obtain a waiver of this section to allow certified, unlicensed personnel to administer medications in a residential facility which 16 or more persons reside as noted in Section 17a-210-1 (o) of these regulations.

Discussion:
Regions seeking approval for the use of certified unlicensed personnel in facilities which require commissioner approval, shall submit documentation in writing to the central office director of health and clinical services stating the name of the facility and the reason for the request. The director will confer with the Office of the Attorney General and make recommendations to the commissioner. The commissioner shall respond in writing with either a denial of request or approval with terms and conditions as appropriate.

Discussion
Medications may be administered as ordered by other legally authorized prescribers such as a physician's assistant, an advance practice registered nurse, etc. Discussion throughout the remaining document shall include these additional practitioners.

When a prescriber determines that training of unlicensed personnel is inadequate to administer medication safely to a client, the following criteria shall be met:

1. the order shall be on a client-by-client basis;
2. the order shall be written as a doctor's order;
3. the order shall be accompanied with physician rationale for medication administration only licensed personnel; and
4. the order and rationale shall be reviewed and renewed every 90 days by physician.

Discussion:
Over-the-counter is defined as any medicinal preparation which may be purchased without a written prescription presented to a pharmacist. All over-the-counter medications being administered to the client must have a written physician's order documented in the client's record per Section 17a-210-6. Over-the-counter medications may be purchased in bulk supply as long as client-specific physician orders are in place in the client record. For clients who self administer medications, see Section 17a-210-4.

Discussion
Prescription medication for one client cannot be borrowed for administration to another client.

Discussion
The agency's written procedures will reflect actions relative to any medical emergency as a result of medication administration. Emergency numbers shall be readily available. All other information shall be readily available on site to all staff.

Agency procedures shall define the method of documenting a medication emergency and reporting to DMR when appropriate per DMR policy.

Discussion
Per CTH regulations Subsection (a)(h) of Section 18a-227, the CTH licensee shall provide a "responsible designee who is available at all times if such supervision is necessary as documented in the overall plan of services." Neither the CTH licensee nor the designee make emergency medical decisions. The person responsible, if other than the client, shall be identified in the client's overall plan of service and shall be readily available.

Discussion
The physician's request for supervision by licensed personnel of the initial medication administration shall accompany the prescription and/or be documented as part of the physician's written order. The agency's policy will determine how the initial administration shall occur under the supervision of licensed personnel when required by the prescribing physician.

The facility or agency delegating nurse shall provide and document additional training to certified unlicensed staff prior to such staff administering medications via gastrostomy or jejunostomy tube (per agency policy and procedure).

Discussion
Orders for prescription medication may be written for up to 180 days which includes refills except where stricter regulations apply, e.g. ICF/MR standards, or unless otherwise specified by the physician.

Discussion

Agencies shall have a procedure that identifies the mechanism for communicating new orders or changes in medication regimens which occur during the day program. The department strongly advises that any changes in medications, even when medications are not to be given during the day program or recreational outing, be communicated to the appropriate parties to ensure client health and safety.

Discussion
The intent of this regulation is not to utilize authorized persons in lieu of unlicensed certified personnel but to support involvement in the community with families and friends. Agencies shall have written policies or procedures which address how to handle multiple dosages of medication administered at another site including tracking and documenting medications transported, procedures to be followed if discrepancies occur in transport, and identifying the responsible person.

Discussion
Agencies shall have written policies which address:

• the method for tracking and documenting medications transported from one location to another, including identifying the responsible person and procedures to be followed if discrepancies occur in transport;

• the method for handling situations where individuals other than certified unlicensed staff may administer medications on specific trips, home visits, or other similar activities with "authorized persons" such as volunteers, family members, friends, or other similar individuals; and

• how the agency defines "authorized person" for the specific client for each excursion.

Discussion
Agencies shall develop policies and procedures which specify personnel actions to be taken in addressing errors in medication administration in the following classes:

Agency policies shall include:

1. the mechanism for reporting to supervising nurse or physician and other designated individuals;
2. procedures for obtaining treatment for involved client;
3. corrective action to be taken if three (3) errors are made within 30 days from the initial error; and
4. the method for tracking errors made and corrective actions taken, from the employee's date of certification to his or her annual certification evaluation and biannual recertification.

Agency policies will be reviewed at the time of inspection or by the DMR regional health service director and/or the DMR central office director of health and clinical services.

Department of Mental Retardation (DMR)-operated facilities shall adhere to procedures and sanctions outlined in the Criteria for Assessment of Medication Administration Errors (See Attachment A).

Discussion
DMR's procedure and format for incident reporting shall be utilized for all medication errors. Class C errors require immediate notification to DMR regional health services director and the Division of Quality Assurance. Per licensing regulations, the DMR regional director shall be notified when the medical treatment included hospitalization.

(1) Theory

Discussion
This component shall be taught by a registered nurse, pharmacist or physician who is licensed pursuant to Connecticut General Statutes and who has experience in training persons to administer medications. There are three (3) options to prepare for the written exam for the medication administration certification program. They are:

A letter of recommendation must accompany the registration packet. Using the above criteria, the agency Executive Director or Regional Director must identify in what ways a staff person using option C meets the criteria. Any registration packet submitted without the letter of recommendation will be denied certification until all appropriate requirements have been met.

*It is strongly advised that the employee study, be tutored,, or receive a refresher course prior to taking the exam through Option C.

People participating in the 21 hour department-approved program through Option A (DMR or it's designee) or Option B (endorsed instructor) will complete the training program and take the exam. If the person fails, he or she may retest. Options to prepare for the retest are:

• repeat the 21 hour program,
• take a refresher class,
• self study, and/or
• tutorial assistance by agency nurse.

This decision will be made on a case-by-case basis with the employee and the appropriate agency personnel (i.e. RN, residential supervisor, etc.) or according to the agency policy.

If the person fails the second attempt, he or she may retest one more time. Options to prepare for this third test are the same as above. If the person fails on the third attempt, he or she begins the process again.

People participating in Option C (test in) will take the test without completing the DMR approved 21 hour program with the following test criteria:

A person is limited to a total number of six (6) attempts (tests) for certification. Further requests for considerations for entry into a 21 hour course and/or testing shall be made in writing to the central office medication administrator coordinator, the executive director or DMR regional director, including the rationale for such request.

Registration for Option A:
People must register with the DMR regional medication administration coordinator at least five (5) days in advance of course or test dates. The agency shall ensure that the registration form is complete, including any additional required documentation such as executive director recommendation (drug-related conviction) and/or RN recommendations (lack of high school diploma or GED), and shall retain the original and send a copy to DMR or it's designee.

Testing for all Options:

The regional medication administration coordinator will send test scores to each agency contact person.

See Attachment B for a complete outline of the application process including required forms.

(2) Laboratory Practicum

Discussion
This component shall be taught by a registered nurse, pharmacist or physician who is licensed pursuant to Connecticut General Statutes with experience in training persons to administer medications. The laboratory practicum consists of:

• demonstration of administration and documentation procedures;
• return demonstration of administration and documentation procedures by the employee; and
• successful completion of a competency checklist.

The DMR's (or the DMR designee's) instructor will do the lab practicum along with the theory.

An employee who "tests in" must also complete the laboratory practicum. There are two options for doing this:

Documentation of the employee's successful completion shall be attached to the application packet and sent to the DMR central office medication administration coordinator.

(3) Worksite practicum under the supervisor of a registered nurse

Discussion
This component shall be done by the provider agency's registered nurse (referred to as the supervising nurse in the regulations) who per regulation, shall supervise the unlicensed, certified employee on an ongoing basis as defined in Section 17a-210-7a of these regulations. The on-site practicum consists of:

• an orientation to medications, procedures, and systems at the participant's actual worksite;
• demonstration of administration and documentation procedures; and
• successful completion of a competency checklist.

All persons enrolled in the certification training program must complete an on-site practicum.

Documentation of successful completion (i.e. Checklists A and B) shall be attached to the application packet and sent to the DMR medication administration coordinator

Training shall be provided that is specific to the needs of the clients in residence. A community training home provider may be required by a physician or a regional director to complete a course of instruction in or demonstrate a proficiency in the administration of medication, including requiring such provider to attend the training program provided for herein.

Each residential facility and day program shall select the employees to be enrolled in the training program. Such employees shall be admitted to the training program if they are high school graduates or otherwise qualified to participate in such program and if such employees are approved by the department. A person convicted of a crime involving the manufacture, sale, dispensing, possession, or possession with intent to sell any controlled substance may be denied admission to the training program if after considering (1) the nature of the crime and its relationship to the position to which the certificate applies; (2) information pertaining to the degree of rehabilitation of the convicted person; and (3) the time elapsed since the conviction it is determined that such person is not suitable for admission.

Discussion
Each agency, with it's employee, decides through which option the employee will participate and register the employee with the DMR regional medication administration coordinator. Each agency determines which eligible employees will participate in the program. The department strongly recommends that agencies obtain police checks for drug-related convictions prior to completion of the certification process.

DMR requires the use of the attached registration form (See Attachment B).

If a registrant indicates on registration form that he or she has a drug-related conviction, a letter from the agency executive director (private) or the regional director (DMR) which documents the administrative decision to recommend the registrant for training despite the drug conviction, must accompany registration form (See Attachment B).

If a registrant indicates on the registration form that he or she has had a previous medication certificate revoked, a letter from executive director (private) or regional director (DMR) which documents the rationale for recommending retraining for the registrant, must accompany the registration form.

Agencies retain, and keep secure, all paperwork including registration forms until course, test, lab and on-site practicums are successfully completed and send the originals which comprise the application packet to the DMR central office medication administration coordinator.

The training program provided for in Sections 17a-210-1 to 17a-210-9, inclusive, shall be taught by a registered nurse, licensed pursuant to Chapter 378 of the CGS, a pharmacist, licensed pursuant to Chapter 382 of the CGS or a physician licensed pursuant to Chapter 370 of the CGS, with experience in training persons to administer medications.

Discussion
To become an endorsed instructor one must be a registered nurse, pharmacist, or physician with a current license as defined by Connecticut State Statutes, demonstrate experience in teaching people, and demonstrate experience of knowledge in the area of developmental disabilities. Applications may be obtained from the DMR central office medication administration coordinator in the planning and development group and upon completion be sent back to central office. The coordinator will notify the applicant of acceptance and the regional coordinator will provide materials and resources. (See Attachment C for detailed information on instructor qualification and application process.)

Each person who successfully completes the training program specified in subsections (a) and (b) of this section shall be issued a certificate authorizing him or her to administer medication to clients.

Discussion
See Attachment B for complete instruction packet including forms and checklists. Use of forms provided in Attachment B is required.

Option A (DMR or DMR Designee/agent): agency retains original registration form and sends copy to the DMR designee with the employee. The lab practicum sheet and test results will be sent to the DMR regional coordinator from the DMR designee. The regional coordinator will send the lab practicum sheets and test results to the appropriate agencies. The exam answer sheets will be sent to the DMR central office medication administration coordinator by the DMR designee.

Option B (21-hour endorsed instructor course): endorsed instructor contacts the regional coordinator to get participant handbooks and lab practicum supplies. Upon completion of the theory training and the laboratory practicum, the instructor notifies the DMR regional coordinator to register the employees for exam. The agency retains original paperwork.

Option C (alternate department-approved program): agency schedules the lab practicum with an endorsed instructor or through the DMR or DMR's designee. The agency registers employees for exams as in Option B through the DMR regional coordinator.

The agency retains all paperwork including registration form until successful completion of course, test, and lab and on-site practicums. The agency retains copies and forwards the originals to the DMR central office medication administration coordinator.

The DMR central office coordinator reviews paperwork, including original examination data, types certificates, logs information in the computer, files paperwork, and sends the certificates to the private agency or DMR regional coordinator as appropriate. The certification date is the date of the successful completion of the on-site practicum.

Central office maintains a list of certified, unlicensed personnel. Agencies who wish to verify certification of new employees may contact:

Agencies' procedures shall include:

• maintaining copies of paperwork,
• making copies of certificates prior to sending to employees, and
• maintaining all paperwork and certificate copies in appropriate, secure files.

Discussion
The medication administration certificate expires every two years. A person must become recertified if he or she intends to continue administering medications in any day program or residential facility as defined in the regulation. No one may continue administering medications beyond the expiration date indicated on the certificate.

For each employee, agencies shall track the employee's certification expiration date provided on the certification card. If the employee does not have a card, the agency coordinator should contact the DMR central office medication administration coordinator for identification of current certificate status and issuance of a verification letter. A person may not administer medications without a valid current card or DMR central office verification letter, in hand.

The department strongly advises that prior to recertification, agencies conduct a police check for drug-related convictions that may have occurred during the person's current certification. If a record of a drug-related conviction is discovered or a registrant indicates on the registration form that he or she has had such a conviction, a letter from the agency executive director (private) or DMR regional director which documents the administrative decision to recommend the registrant for recertification despite the drug conviction must accompany the registration form.

There are two components to the recertification process: a written examination and an on-site practicum which must be completed within 90 days prior to the employee's certification expiration date. There is no order in which the exam and on-site practicum must be completed.

The DMR central office medication administration coordinator will process the application and issue the certificate.

 Anyone who does not complete the requirements for recertification prior to his or her expiration date must complete the requirements for an initial certification which are: pass a written exam; pass a laboratory practicum; pass an on-site practicum; and submit a registration form and required paperwork to the DMR central office medication administration coordinator. Exceptions will be made for people whose certificates expire while on an approved leave of absence or during a period of non-employment in the field of mental retardation. People in these situations have up to one year to complete the requirements for recertification. However, upon return to work, they cannot pass medication and must complete their recertification within 90 days.

Completing the Recertification Registration Form (See Attachment B)
Most sections of the registration form are self explanatory. The following is a description of sections that may not be self explanatory:

Part 1 - to be completed by employee. Demographic information: self explanatory.
1) If an employee's certification card has expired prior to completing the certification process, explain why. People whose certification card has expired while on a leave of absence or during a period of non-employment in the field of mental retardation have one year in which to complete the recertification process. All others whose certification has lapsed must go through the process for initial certification.

2) If an employee has a drug-related conviction since his or her initial certification or last recertification, refer to Directive 90-1 (See Attachment D) and attach a letter with the necessary information and recommended action to the registration form.

Part 2 - to be completed by agency supervising nurse or administrator.
Agencies attach the exam answer sheet, Checklists A and B, and a letter regarding any drug-related convictions that have occurred since certification or last recertification (See Directive 90-1, Attachment C, if applicable); sign and date the form to indicate the information is true and complete to the best of your knowledge.

NOTE: If the person is in the process of certification revocation, do not submit paperwork for recertification until an outcome has been determined

 (A) the department finds that the applicant successfully completed a training program substantially similar to or of greater scope than that required by the department;

(B) the applicant submits the certificate or equivalent documentation to the department for purposes of verification; and

(C) such certificate or equivalent documentation was issued no later than two years preceding the date of the application.

Discussion
The registration form and documentation/verification of equivalent training must be submitted to the DMR central office planning and development division. Employees shall not administer medications in Connecticut until a Connecticut DMR certificate is issued.

Clients who are able to self administer medication, as defined in these regulations, may do so, provided a physician writes an order for self administration.

Discussion
The client must be able to identify medication by size, color, amount or other label identification. He or she must be able to identify time of day medication is administered, independently or with employee prompt or adaptive device, such as alarm clock or medication dispenser. Staff providing such (indirect) assistance do not have to be medication certified when the client is fully self medicating. However, if any direct assistance or supervision by staff is necessary, such staff shall be medication certified.

Supervision of self-administration program training to the client shall be provided by the supervising nurse or certified unlicensed staff. It is strongly recommended that the IDT acknowledges and evaluates the client's ability to self medicate at the time of the OPS.

Agency procedures shall indicate how they will address over-the-counter medications for those clients who self administer their own medications.

Discussion
All medications must be self contained and properly packaged in a locked area. Controlled substances shall be stored as outlined in Connecticut Regulations of State Agencies, Department of Consumer Protection, 21a-252-10 (See Attachment E).

Discussion
"Authorized" is defined as certified and/or licensed in this section.

Agency procedures shall include the process for handling keys and security procedures to limit access to certified and/or licensed staff. The list of persons authorized to administer medications shall be updated annually and need not be posted, but must be available upon request. Copies of staff medication certificates shall be maintained in the facility.

Discussion
Agencies shall have a written procedure that details the way individual client medications are stored and that includes the nurse determination that storage poses no threat to health and safety of other residents. The supervising nurse shall provide necessary documentation if unlocked storage is permissible.

Discussion
Agencies shall provide a written procedure for drug disposal and identification of individuals designated with authority to destroy medications and ensure that appropriate documentation is available. It is strongly recommended that licensed staff witness drug destruction on all occasions.

Discussion
Agencies shall provide a procedure which includes all elements of documentation requirements.

Discussion
Copies of dental and other practitioner orders shall also be retained in client file.

Discussion
Verbal and/or telephone orders are to be communicated to licensed persons (RN, LPN, or Pharmacist) only. Such orders shall be client specific, indicate purpose, amount and duration of order, and include pertinent information to allow appropriate implementation. Orders may be communicated per the following:

1. Telephone orders: Telephone orders are defined as orders given by a physician or other authorized prescriber to a licensed person (RN, LPN, or pharmacist) over the telephone which must be documented on an order sheet by the licensed person who accepted the order. These orders shall be countersigned by the prescriber no later than two weeks (14 days) from date of receipt. For the purpose of these regulations, the term "verbal order" should be interpreted to mean a telephone order.
2. Verbal orders; Verbal orders are defined as orders given to a licensed person (RN, LPN, or Pharmacist) while in the presence of the prescriber. The department advises that the prescriber be asked to write the order rather than accepting a verbal order. If a verbal order is taken, it shall be documented on an order sheet by the licensed person who accepted the order and shall be countersigned by the prescriber within the time frames given in number 1, above.
3. Faxed orders: Faxed orders are defined as written orders by a physician or other legally authorized prescriber that are sent via facsimile machine to the person's home or pharmacist. Such orders, previously considered to be telephone orders, are now considered original orders and therefore, do not need to be countersigned by the prescriber.

(See Attachment F: DMR Health Bulletin #97-1 (Revised July 1999), Medication Ordering Guidelines for DMR Licensed/operated Facilities.)

Discussion
Medication documentation records are retained as part of a client's permanent medical record. (Physician's orders, progress notes and laboratory and diagnostic test results are also considered to be a medical record which must be maintained as part of the client's permanent record.)

A copy of medication record from day program must be returned to residential client file.

Discussion
For number 7) above, employee signatures means the employee's full, legal signature. Medication names shall not be abbreviated and shall be documented on the prescription. If the medication is abbreviated on the pharmacy label, the kardex must contain both the full name and abbreviated name. If the prescription has the medication trade name and the pharmacy label has the generic name, the kardex must list both names.

Client cooperation shall be documented only when the client is resistive or non compliant. This is considered to be a client unusual incident, not an employee medication error. Agency policy should address how to address client resistance or non-compliance that occurs frequently.

Discussion
Agencies shall have procedures for receipt of controlled substances from pharmacies and staff documentation procedures including the location of receipts and disposition forms.

The supervising nurse shall document regular (at least quarterly) review of controlled substance receipt and disposition as required in Subsection 7 (3) of these regulations.

l) The client's name
2) The prescription number
3) The prescription date
4) The name of the pharmacy
5) The name of the prescribing physician
6) The date of receipt of the controlled substance
7) The quantity of the controlled substance
8) The name of the medication
9) The dosage
10) The form of the medication
11) The signature of the employee who received the controlled substance
12) The frequency of administration
13) The route of administration
14) The renewal date of the prescription
15) The initials and signatures of employees who have administered the medication
16) The month, day, year, and time the medication was administered
17) The amount of medication remaining
18) The expiration date of the prescription
19) Client allergies to food and medication

Discussion
Agency policies and procedures shall indicate the method and frequency of control drug counts. It is strongly recommended that a count be conducted on each shift that medications will be administered. Control drug counts shall be done only by medication certified staff.

 Agency policies and procedures shall indicate the process for reporting and investigating incorrect control drug counts, including reporting missing drugs to the DMR Regional Health Service Director.

(1) Supervise the initial worksite administration of medications by certified unlicensed personnel and document such supervision.

Discussion
The initial administration of medications shall be observed by the supervising nurse or physician at the employee's worksite and documented on Checklist B. The supervising nurse's observation that occurs during the on-site practicum, if successfully completed, constitutes "supervision of the initial worksite administration of medications."

The supervising nurse or physician shall supervise and document an initial worksite administration of medications by any employee who holds a current certificate and is newly employed by the agency. Documentation of this observation completed by the supervising nurse shall be maintained as per agency policy.

(2) Make periodic observations of the administration of medications by certified unlicensed personnel at least annually and document such observations.

Discussion
Subsequent to the initial worksite observation, the supervising nurse shall observe each certified unlicensed personnel administer medications at least once annually at the employees usual worksite. This annual observation shall be done one year prior to the certificate expiration date (plus or minus four weeks). Documentation of the supervising nurse's observation shall be maintained as per agency policy. The department advises use of Checklist B as the documentation tool. Such documentation shall be made available upon request.

(3) Monitor and document on an ongoing basis, but at least quarterly, documentation pertaining to the administration of medication. Review shall include, but not be limited to: (a) physician or dentist orders; (b) medication bottle labels and medications listed on the medication record and receipt and distribution form or forms to determine whether they match the orders of the physician or dentist and (c) the medication record and receipt and disposition form or forms to ensure that they contain the following information: medication error documentation; whether medication was administered as prescribed; compliance or noncompliance of the client; the existence of full signatures for all initials used by persons documenting the administration of medication.

Discussion
At least four times a year on a quarterly schedule, the supervising nurse shall review documentation to ensure the following:

• orders are current and transcribed to medication record correctly;
• pharmacy labels match physician's orders;
• controlled substance receipts and disposition forms match prescriber's orders;
• all components of Sec. 6 A-J are in compliance and
• employee full signatures (employee's legal signature and title) are present.

If the record review shows that a client demonstrates a pattern of noncompliance with medication administration as determined by agency policy and procedure, a referral should be made to the IDT to review and address.

(4) Submit a written report to the appropriate regional health services coordinator if such physician or nurse has information which appears to show that:

(5) Such physician or nurse may rely on information concerning the performance of certified unlicensed personnel acquired as a result of complying with the requirements set forth in subsections (1), (2), and (3) of this section in making a determination as to whether a report should be submitted pursuant to subsection (4) of this section. Such persons may also rely on the incident reports documenting errors in the administration of medications in making such a determination.

Discussion
Basis of report reflects noncompliance of requirements as outlined in Sections (7) (a) (1),  (7) (a) (2), and (7) (a) (3).

Agencies shall adhere to DMR incident report procedures and shall use incident report forms in providing supporting documentation.

(6) Such report shall include, but not be limited to, the following information:

Discussion
Upon receipt of submitted reports, submitted on the DMR Certified Unlicensed Personnel Sanctions Request Form (See Attachment G), the regional health services directors shall:

• review the documentation and recommendations;
• state their conclusions;
• make written recommendations to the central office director of health and clinical services for review on the sanctions request form; and
• send copies to the appropriate DMR or private agency manager and for DMR employees to personnel.

The director of health and clinical services shall:

• review documentation, requesting further information as necessary;
• make written recommendation; and
• forward these recommendations to the commissioner for final action.

Discussion
Upon receipt of the director of health and clinical services recommendations, the commissioner of DMR shall determine the sanction to be imposed, such as: suspension, probation, revocation and shall notify the person via certified mail, with copies to the central office medication administration coordinator and to other appropriate DMR or agency staff and/or managers such as DMR personnel (for DMR employees).

Only the commissioner may revoke or suspend certification issued by the department. Actions by the commissioner concerning and individual's certification are separate and distinct from any progressive disciplinary action which may be taken by an employer.

Discussion
If abuse or neglect of a client is suspected, the incident shall be reported and investigated pursuant to Sections 19a-458, 17-135 or 17-38a and/or PA 97-2 as amended by PA 133 of the C Connecticut General Statutes. With the exception of Class C errors which shall automatically be reported for investigation in the abuse/neglect system, medication errors will be addressed through the medication error sanction process and would NOT rise to the level that would warrant report and investigation in the abuse/neglect system.

Any person aggrieved by the decision of the commissioner to revoke or suspend a certificate in any way may, within twenty (20) days after receipt of a notice of revocation or suspension of a certificate, submit a written request to the commissioner for reconsideration of his or her decision. Within twenty (20) working days after receipt of such request, the commissioner or his/her designee shall conduct an informal hearing, at which the health services coordinator and the employee may present written or oral evidence.

The commissioner or his/her designee shall render a decision within twenty (20) working days after the hearing. The decision of the commissioner or his or her designee shall be final. Revocation or suspension of a certificate shall be stayed pending the outcome of such hearing except where the health services coordinator has determined that the continued administration of medication by the aggrieved employee would threaten the life, health or safety of a client or clients. In the absence of a request for a reconsideration during this time period, the certificate shall either be revoked or suspended.

Discussion
The commissioner or his or her designee shall inform the person of the informal hearing via certified mail, with copies to the appropriate agency personnel, DMR regional health services director and the central office medication administration coordinator and director of health and clinical services. The commissioner or his or her designee shall consult the Office of the Attorney General as appropriate. The DMR regional health service director, the person's supervising nurse, and other appropriate agency personnel shall attend the informal hearing to provide additional written or oral evidence.

The commissioner or his or her designee shall inform the person of his or her final decision via certified mail within 20 working days of the informal hearing, with copies to the central office medication administration coordinator, the director of health and clinical services, the DMR regional health service director, and other appropriate DMR or agency staff and managers.

Copies of all sanction requests and decisions shall be maintained in a confidential file.

Attachment A: Criteria for Assessment of Medication Administration Errors
Attachment B: Complete outline of the application process including required forms
Attachment C: Detailed information on instructor qualification and application process
Attachment D:
Attachment E: CT Regulations of State Agencies, Dept of Consumer Protection, 21a-252-10
Attachment F: DMR Health Bulletin #97-1
Attachment G: Report of Non-Compliance with Medication Regulations, and DMR Certified Unlicensed Personnel Sanctions Request Form