The New Jersey Department of Education has received several inquiries regarding scenarios when it is permissible for a school nurse to delegate medication administration to other staff members in a school setting.  A memorandum aims to eliminate confusion that could lead to inconsistent practices and place students and staff members at risk.

The New Jersey Board of Nursing provides oversight regarding nursing practice, including licensing, regulations for safe ethical practice and discipline for nurses who violate regulations. The NJDOE recognizes that through the licensure granted by the Division of Consumer Affairs and the NJBON, it is within a registered nurse’s scope of practice to delegate medication administration.

The memorandum notes, however, that school nursing is a separate and distinct specialty. The credentials of a certified school nurse in New Jersey signify a registered professional nurse with advanced professional nursing knowledge and clinical skills specific to the school setting. The certified school nurse must be directly employed by the district board of education and cannot be employed through a contract with a third party. Consequently, a certified school nurse hired by a local educational agency is providing school health services through both their licensure as a registered nurse and certification as a certified school nurse, whose practices are governed by regulations administered by both the NJBON and the NJDOE.

The regulations administered by the NJDOE specify how nursing practices are allowed to be implemented within a school setting.

Pursuant to N.J.A.C. 6A:16-2.1(a)2, school health services provided in a school setting restrict the individuals permitted to administer medication to students to certain individuals, who are outlined in the memorandum.

In certain circumstances, there are statutes enacted that specifically require school nurses to delegate medication, allow or require other members of a school community to administer specific medications, which are also outlined in the memorandum.

The memorandum notes that as per N.J.S.A. 18A:40-3.3, a local educational agency may supplement the services provided by the certified school nurse with noncertified nurses, provided that the noncertified nurse is assigned to the same school building or school complex as the certified school nurse.

In addition, there are circumstances that allow LEAs to hire licensed practical nurses. An LPN’s practice within the scope of their education and training includes medication administration. LPNs are not trained or educated in assessment of illness or injury. An LPN does not work independently, but rather may be employed by an institution or organization and supervised by the certified school nurse. The board of nursing explains that supervision may require the direct continuing presence or the intermittent observation, direction and occasional physical presence of a registered professional nurse. Whether supervised directly or indirectly by a registered nurse of certified school nurse, LPNs are responsible for professional acts and accepting assignments in which they are competent.

LEAs and district boards of education are reminded that, in order to protect the health and safety of students, N.J.A.C. 6A:16-2.1(a) requires each district board of education to develop and adopt written policies, procedures and mechanisms for the provision of health, safety and medical emergency services, and shall ensure staff are informed as appropriate. This includes the provision of health services in emergency situations, including the care of any student who becomes injured or ill while at school or while participating in school-sponsored functions.

Read the memorandum for complete information.

Questions may be directed to the NJDOE via email.