Practice Information

Prefilling Medication Boxes in Home Care Settings


To: Home Health Care Providers Regulated under New York State Public Health Law Article 40, Hospice Care and Article 36 which includes: Certified Home Health Agencies, Licensed Home Care Services Agencies, Limited Licensed Home Care Services Agencies, and Long Term Home Health Care Programs

From: Barbara Zittel, RN, Ph.D, Executive Secretary to the State Board for Nursing and
Lawrence Mokhiber, R.Ph., Executive Secretary to the New York State Board of Pharmacy

Subject: Pre-filling of Medication Containers for up to Fifteen Days

Date: May 2010


In December, 2009 the Governor signed into existence Chapter 503 of the Laws of New York State which provides the following:

Notwithstanding any provision of law or regulation to the contrary, the commissioner of education, in consultation with the state board for nursing and the state board of pharmacy, shall promulgate guidelines which allow for the prefill of up to a fifteen day supply of medication prescribed by a physician or other authorized practitioner and provided to an individual by a registered professional nurse for individuals receiving home care services ordered by an authorized practitioner and provided under the supervision of a registered professional nurse.

Based on this law, registered professional nurses (RNs) and, as clarified below, licensed practical nurses (LPNs) functioning under an RN’s supervision, may prefill medication boxes for up to a fifteen day supply.

The State Board for Nursing and the State Board of Pharmacy have prepared the following guidelines for use by home care nurses. These are not promulgated regulations but are provided as a “best practice” guide for use in conjunction with nurses’ professional judgment and the orders of the physician or other authorized practitioner in implementing this policy.

  • This provision applies only to individuals receiving home care services ordered by an authorized practitioner such as a physician or nurse practitioner (NP).
  • This guidance applies to the prefill of medications that are prescription drugs that have been dispensed by a pharmacist, and over-the-counter drugs, vitamins, food supplements, etc., that have been ordered by an authorized practitioner.
  • There must be a patient specific order for each medication to be prefilled by an RN or RN-supervised LPN.
  • No more than a fifteen day supply of medication can be prefilled. However, this is not to imply a universal standard of a 15 day supply for all prefill patients, as any supply up to 15 days should only be as appropriate to a specific patient.
  • The RN in accordance with her or his professional judgment must assess the appropriateness of a patient for medication prefills given the number of medications to be prefilled and the related complexity of the labeling scheme. Prefilling medications may not be a safe alternative for some patients. In the case of a non self-directing patient, the patient must have a self-directing caregiver able and appropriate to assist the patient with the administration of prefill medications.
  • RNs must determine a method of proper identification of each medication for the patient and/or caregiver, which could be a log, a picture, a chart or other means. Of particular concern is correctly identifying medication that must be taken several times a day, at specific times of the day, with or without certain foods or liquids, or medication with specific instructions such as “take with a full glass of water, on an empty stomach and do not lie down for 30 minutes”. Identification of medications must be clear enough for a patient or caregiver to easily respond to a determination to “hold” or discontinue one of several drugs packaged together.
  • In determining the appropriateness of a medication for prefill and/or the appropriateness of a prefill container, the RN should consider whether a medication requires special packaging or storage so that it is not placed into an inappropriate container. An example of this would be nitroglycerin, which must be stored in glass containers only.
  • Consideration of the household environment should be given as to whether controlled substances should be stored with non-controlled substances or in a secure locked environment.
  • In group or adult home settings, an RN must determine the best method to assure appropriate storage of the medications, taking into consideration variables such as labeling and the inadvertent or intentional use by other patients.
  • The RN will have to consider how best to handle those medications which are to be administered only “prn”, that is, as needed and the introduction of new medications. Prefilling may not be appropriate in such situations.
  • The patient and/or caregiver must be instructed as to what procedure to follow should an incident occur with the medication box, such as spillage, etc.

After an initial assessment of the patient by an RN and under the supervision of an RN, a Licensed Practical Nurse (LPN) may be permitted to prefill medication boxes provided that:

  • The RN and LPN consider the previously cited “best practice” guidance.
  • The first prefill procedure for a patient must be performed by an RN.
  • An RN must provide written documentation of the competence of the LPN as specified in the employing agency’s policy.
  • The RN periodically, but no less than every 60 days, reassesses the degree to which medications are efficacious and the degree to which the patient/client remains self-directed.

RNs and LPNs should also consider the following additional best practice guidance:

What is critical for the safety of the patient when implementing this provision is determining the extent to which a patient and/or the patient’s caregiver is self-directed. In most situations, that determination is made by the RN assessing the patient. Suitable patients are those who are themselves able to demonstrate or who have a self-directing caregiver who is able to demonstrate consistently the ability to self-medicate once the container (medication box or syringe) is adequately prepared by an RN. In all such circumstances patients and/or a self-directing other, should be capable of providing orally or by other means, such as a written list or chart, the names of the medications taken by the patient, the time that they are to be taken, significant side and untoward effects, and whether or not such effects are occurring.

We hope this is helpful. If additional questions arise, please contact Barbara Zittel, RN, Ph.D., Executive Secretary to the State Board for Nursing, by mail, at: 89 Washington Avenue, Nursing Board Office, Second Floor, West Wing, Albany, NY 12234; by e-mail, at: nursebd@nysed.gov; or by phone, at: 518-474-3817 ext. 120.

Last Updated: January 31, 2013