Argentum in late December sent a letter to the Environmental Protection Agency outlining its support for agency efforts in ensuring proper handling of hazardous waste pharmaceuticals in a long term care setting but expressing concern over certain language in a proposed rule.
The EPA has proposed including state licensed assisted living communities in its definition of LTC facilities “which will result in impractical implementation of several provisions of the proposed regulation,” wrote Argentum COO Maribeth Bersani. She notes that some of the larger assisted living communities may have contracts with a preferred pharmacy, but that’s not standard practice in the 20,000 smaller communities where residents select their own pharmacy – and there are even a few state licensure categories prohibiting assisted living communities from managing medications. Additionally, a staff member may not enter a resident’s room without permission and would have no authority to go into the room for the purpose of disposing the resident’s medication.
“Therefore, AL communities would not have the authority to compel residents who select their own pharmacy or manage their own medications to surrender their medications for disposal,” making AL communities perpetually in noncompliance with the EPA’s proposed rule.
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