Hello Sheila,

Our local GP surgery has a pharmacy but would be unable to provide MAR sheets for administering medication to our service users if we used their services instead of our current larger but more distant pharmacy. We are a registered residential care home for vulnerable adults. What is CQC’s view on us producing printed MAR sheets ourselves containing all the required information?

Answered by Sheila Scott

Dear Andrew,

This is an important question that you ask. The decision is yours and not CQC’s. I believe that CQC would ask themselves the question “Are the arrangements that you have made safe?”

The legal position is:

Health and Social Care Act 2008 (Regulated Activities) Regulations 2014

12.—

1. Care and treatment must be provided in a safe way for service users.
2. Without limiting paragraph (1), the things which a registered person must do to comply with that paragraph include:
   1. Assessing the risks to the health and safety of service users of receiving the care or treatment;
   2. Doing all that is reasonably practicable to mitigate any such risks;
   3. Ensuring that persons providing care or treatment to service users have the qualifications, competence, skills and experience to do so safely;
   4. Ensuring that the premises used by the service provider are safe to use for their intended purpose and are used in a safe way;
   5. Ensuring that the equipment used by the service provider for providing care or treatment to a service user is safe for such use and is used in a safe way;
   6. Where equipment or medicines are supplied by the service provider, ensuring that there are sufficient quantities of these to ensure the safety of service users and to meet their needs;
   7. The proper and safe management of medicines;
   8. Assessing the risk of, and preventing, detecting and controlling the spread of, infections, including those that are health care associated;
   9. Where responsibility for the care and treatment of service users is shared with, or transferred to, other persons, working with such other persons, service users and other appropriate persons to ensure that timely care planning takes place to ensure the health, safety and welfare of the service users.

This is the guidance from CQC

12(2)(g) the proper and safe management of medicines:

• Staff responsible for the management and administration of medication must be suitably trained and competent and this should be kept under review.
• Staff must follow policies and procedures about managing medicines, including those related to infection control.
• These policies and procedures should be in line with current legislation and guidance and address:
  • Supply and ordering;
  • Storage, dispensing and preparation;
  • Administration;
  • Disposal;
  • Recording.

This guidance is helpful I believe. It is clear that you need to have the appropriate policies and procedures in place, that the staff handling medication have to have the appropriate training and that the recording of medication to service users has to be properly completed.

This can all of course be done whether you use the pharmacy’s MAR sheets or your own.

Additionally the questions that The Key Lines of Enquiry asks can be found here and if you look at S4 you will see it is up to you to make the arrangements and that you need to be able to demonstrate that they are safe.

http://www.cqc.org.uk/sites/default/files/20140924_asc_residential_kloe_prompts_and_sources_of_evidence_column_final_v1-0.pdf

I hope this is helpful.

Best wishes.

Sheila