Expired medications have been saved and repurposed for mock code education. For example, expired pre-filled syringes for mock codes and expired dantrolene for mock malignant hyperthermia drills.
The expired medications are labeled “Expired. Education Only” and are stored in a locked room/cabinet. Even so, there is the potential for inadvertent misuse, etc.
From a regulatory perspective, can you use expired medications for training purposes?
Using Expired Medication for Training
We have seen the Joint Commission score this on surveys when the product is in a training room and is unlabeled. The practice is compliant if these training materials are always labeled and stored in training rooms.
But, if the products are located in a labeled bin, but the product isn’t labeled, you risk an RFI. Further, if the products are individually labeled, but stored with real medications in a medication room or clean utility room, you raise questions in the mind of the surveyor. Although working with genuine products is useful from a training perspective, it’s worth analyzing with nursing to verify:
1. Each product is labeled as expired for training only.
2. Products are stored in training areas only, not in patient care areas.
3. Products are secured from visitors, children and others who may want to divert for personal use.
4. Residual sharps or pharmaceutical waste are deposited in appropriate bins.
Patton Healthcare Consulting
Patton Healthcare Consulting provides a complete range of Joint Commission and CMS Compliance Assistance and a full range of pre-survey and post survey services.
We serve more than 350 hospitals, behavioral health care organizations, ambulatory clinics and home care companies nationwide—hospitals ranging from critical access hospitals to the largest health systems. Contact us at (888) PHC-INC1 for more information.
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