Medication Management in Children's Homes: Policy, Storage & Administration Requirements

Regulation 23 of the Children's Homes (England) Regulations 2015 requires the registered person to make arrangements for "the handling, recording, safekeeping, safe administration and disposal of medicines received into the children's home".

What are the specific duties?

Regulation 23(2) requires the registered person to ensure that:

1. Medicines kept in the home are "stored in a secure place so as to prevent any child from having unsupervised access to them".
2. Prescribed medicine is "administered as prescribed to the child for whom it is prescribed and to no other child".
3. "A record is kept of the administration of medicine to each child."

Under regulation 23(4), "prescribed" means ordered under the National Health Service Act 2006 or a related 2003 provision, or prescribed under regulation 217 of the Human Medicines Regulations 2012. The storage and recording duties cover every medicine kept in the home, over-the-counter ones included. Regulation 23(3) exempts medicine a child can safely keep and take themselves.

Where does the health standard come in?

The health and well-being standard is regulation 10, which requires children's health needs to be met and each child to be registered with a GP and a dentist. Safe medicines handling is part of meeting it; see the nine quality standards.

Medicines must be "stored in a secure place so as to prevent any child from having unsupervised access to them" (regulation 23(2)(a) of the Children's Homes (England) Regulations 2015). The regulation sets the outcome and names no cabinet, lock or room, so your setup must make sense for the children described in your Statement of Purpose.

What does a secure setup include?

This is good practice, not regulation:

• A lockable cabinet fixed to the wall, in a room children do not use unsupervised.
• Separate, labelled space for each child's medicines.
• A lockable fridge, or a locked box inside a fridge, with temperatures recorded.
• Keys held by the shift lead and never left in the lock.
• Medicines kept in their dispensed containers with the pharmacy label intact.

What about arrivals, departures and disposal?

Regulation 23(1) covers medicines "received into the children's home", so record what arrives at admission or from the pharmacy, and what leaves with a child for a visit or at the end of a placement.

Regulation 23(1) also requires arrangements for disposal but prescribes no method. A practical route is to return unwanted medicines to the pharmacy and keep the return record. Schedule 3 paragraph 25(c) requires the child's case record to include details of "the disposal of any medicine".

No regulation restricts who may administer medicines in a children's home. Regulation 23 of the Children's Homes (England) Regulations 2015 requires arrangements for "safe administration"; who gives medicines, and after what training, is yours to decide and justify.

What does the Guide expect?

Paragraph 7.12 of the Guide to the Children's Homes Regulations (Department for Education, 2015) says the registered person must ensure staff "have the relevant skills and knowledge" to "administer basic first aid and minor illness treatment". Paragraph 7.15 says medicines "must be administered in line with a medically approved protocol". Regulation 33(4)(a) requires every employee to "undertake appropriate continuing professional development".

A sound approach is to train every staff member who gives medicines, observe them administering before signing them off, and repeat both at set intervals.

What about consent and as-required medicines?

Paragraph 7.14 says each child should have permission for staff to give first aid and non-prescription medication "from a person with parental responsibility", recorded in the child's relevant plan; for a looked-after child, the social worker arranges it.

Each as-required (PRN) medicine needs a written protocol: what it is for, when it is needed, the dose and the maximum in 24 hours. Paragraph 9.47 of the Guide treats PRN medication not prescribed for a formally identified illness as chemical restraint that "should only ever be delivered in accordance with acknowledged, evidence-based best practice".

Are there other limits?

Regulation 19(2)(d) prohibits "the use or withholding of medication" to discipline a child; see the behaviour management guide. And if someone you employ directly delivers a regulated healthcare activity, Ofsted and CQC joint guidance says that activity must also be registered with the Care Quality Commission.

The record must show every dose given to each child: regulation 23(2)(c) of the Children's Homes (England) Regulations 2015 requires "a record is kept of the administration of medicine to each child". Schedule 3 paragraph 25 makes medicines part of the child's case record: medicines kept for the child, any the child may self-administer, each administration and any disposal.

Which case-record rules apply?

Because paragraph 25 sits in Schedule 3, these entries are case records under regulation 36. They must be kept up to date, "signed and dated by the author of each entry", held securely, and kept for 75 years from the child's date of birth (or 15 years from the date of death if a child dies before 18). Paragraph 7.15 of the Guide to the Children's Homes Regulations adds that records cover "occasions when prescribed medication is refused".

What does a medication administration record hold?

Use a medication administration record (MAR) chart for each child and medicine. These fields are good practice, not a prescribed form:

How do you know the record is right?

Count stock regularly against the MAR charts. A mismatch means a missed signature, a missed dose or a missing tablet. Your policy should say who audits, how often, and what happens next.

The cabinet, register and two-person rules associated with controlled drugs are not legal requirements for a children's home. The storage rules in the Misuse of Drugs (Safe Custody) Regulations 1973 apply to care homes, and a children's home is not a care home under section 3 of the Care Standards Act 2000. The Children's Homes (England) Regulations 2015 do not mention controlled drugs.

Regulation 23 still applies to controlled drugs in full. Any extra control is your decision.

Why add controls anyway?

Some medicines prescribed to children, including some for ADHD, are controlled drugs, so a missing tablet is a safeguarding question. Paragraph 7.17 of the Guide to the Children's Homes Regulations points to Managing medicines in care homes (March 2014), "a guideline that applies across both health and social care". Good practice includes:

• A separate locked cabinet or compartment for controlled drugs.
• A bound register with a running balance for each child's medicine.
• Two staff present and signing for each dose.
• A count at each shift handover.
• Unused stock returned to the pharmacy, signed for by two staff, with a receipt kept.

Support a child to keep and take their own medication when they can do so safely. Paragraph 7.16 of the Guide to the Children's Homes Regulations says such children "should be supported to, if they are able to do so safely", and Ofsted's inspection framework looks for medication arrangements that "promote independence wherever possible".

What does regulation 23(3) allow?

Regulation 23(3) of the Children's Homes (England) Regulations 2015 disapplies the duties in regulation 23(2) for medicine stored by the child "in such a way that other persons are prevented from using it" and that "may be safely self-administered by that child". Both conditions must hold, and your regulation 23(1) arrangements still cover the medicine.

How do you set it up?

1. Assess the child's understanding of the medicine, dose and risks, whether they can lock it away, and any risk to others.
2. Agree it with the child, the placing authority and, where appropriate, the prescriber and family, and record it in the relevant plan.
3. Record it: Schedule 3 paragraph 25(a) requires the case record to show medicines the child may self-administer.
4. Review it at set intervals and whenever anything changes.

It need not be all or nothing: a child can move from doses staff hand over, to a week's supply, to the whole prescription.

Get medical advice for the child first. Paragraph 7.15 of the Guide to the Children's Homes Regulations says that where a home has concerns about a child's medication it should approach an expert "such as a General Medical Practitioner, community pharmacist or designated nurse for looked-after children". In an emergency, call 999.

Is a medication error notifiable to Ofsted?

Not automatically. It is not one of the events specifically listed in regulation 40 of the Children's Homes (England) Regulations 2015. It is notifiable under regulation 40(4)(e), which covers "any other incident relating to a child which the registered person considers to be serious". If you judge it serious, notify Ofsted and each other relevant person without delay. Regulation 40(5) requires the notification to give details of the matter, who else has been told and what you did, and to be made or confirmed in writing.

Seriousness is your judgement. Harm or risk of harm, a dose given to the wrong child, or a repeated pattern all point towards notifying. Record your reasoning either way.

Who else needs to know, and what next?

Tell the child's social worker as the placement agreement requires, the parents where appropriate, and the prescriber or pharmacist. Then find the cause (competency, handover, chart design, storage) and work through it in the supervision regulation 33(4)(b) requires. See the safeguarding policy guide for wider incident handling.

Inspectors look at whether your arrangements are safe and effective and whether your own monitoring catches problems. Among its criteria for a good judgement, Ofsted's Social Care Common Inspection Framework (SCCIF) for children's homes includes that "the manager's arrangements for managing medication or children's complex health needs are safe and effective and promote independence wherever possible".

Do inspectors count the tablets?

Not routinely. The SCCIF says inspectors "do not count medication" unless it is "a specific line of enquiry"; they want to establish that your monitoring systems are "robust enough to identify any strengths and weaknesses in practice". Your audits are that evidence.

What does the framework name specifically?

• In homes for disabled children, "whether staff administer pro re nata (PRN) or ‘as required’ medication appropriately and retain clear records of its administration".
• Where health professionals work on site, "the systems in place to audit the drugs held on site" and the procedures "in the event of mal-administration of medication".

What about registration?

Ofsted's apply-to-register guidance says it will ask to see further policies "at different stages of the process, for example during a site visit", tailored "to the children who will be living in your home". The first inspection guide covers what follows registration.

What should you have ready?

• A medicines policy that matches your Statement of Purpose.
• Training and competency records.
• MAR charts and stock audits.
• Each child's consent for non-prescription medicines.
• Self-administration assessments.
• Pharmacy return records and an error log with actions.