Medication in a Tennessee PSSA: assistance, and administration by certified staff

The PSSA rules define it as "providing medication reminders and opening medication packaging, but does not mean giving the service recipient injections or any form of medication or medication administration" that is only appropriate for people authorized by Title 63, Chapter 7. It includes, but is not limited to (0940-05-38-.01(9)(a)-(g)):

1. Loosening the cap on a pill bottle for oral medication.
2. Opening a pill reminder box, if the client, their authorized representative or a licensed professional filled it.
3. Placing medication within the client’s reach.
4. Holding the client’s hand steady to help them drink liquid medication.
5. Guiding the client’s hand while they put in eye, ear or nose drops, and wiping the excess.
6. Helping with a nasal cannula or oxygen mask, plugging the machine in and turning it on.
7. Applying non-prescription creams and lotions bought over the counter to the outside of the body.

TDMHSAS’s older general definitions rule (last replaced in 2008, before the 2016 PSSA chapter) puts the line plainly: assistance "does not allow the caregiver to give the medication to the individual" (0940-05-01-.01(31)). The PSSA chapter also defines self-administration as "the ability of a service recipient to take prescribed or over-the-counter medications without assistance from another person" (.01(10)). By our reading, the line between the two levels on this page is whether the client can take the medication themselves: assistance helps a client who can, and certified administration is for a client who cannot.

Creams and lotions. Non-prescription creams and lotions are on the rule’s list. Prescription creams, pain patches and ointments of any kind are on TDMHSAS’s not-allowed list (PSSA slide 25; slide 27). Ask TDMHSAS if a product falls between the two.

The policy item applies "if a worker will be providing medication assistance if the licensee provides that service" (0940-05-38-.06(1)(l)). If you do, five duties follow:

The training rule says it must be "consistent with T.C.A. § 63-7-102" (.08(1)(b)). We could not save the Tennessee Code, so we cannot tell you what that section adds; ask your nurse trainer. The rules set no length, curriculum or refresher schedule for medication assistance training. Both RN-supervised training and the authorization are on TDMHSAS’s common deficiency list (PSSA slides 12-16).

CareRulebook’s manual turns these into Policy 2.11, with an authorization form, a medication information form and a training record signed by your registered nurse. A yearly observed check of each worker is offered as recommended practice, labelled as going beyond the rules.

TDMHSAS’s PSSA slides list services that are not allowed under the PSSA license. The medication-related ones include (PSSA slide 25; slides 26-27):

• giving insulin injections, oral medications, prescription topical creams or pain patches;
• filling medication planners;
• putting drops in eyes or ears;
• turning an IV up or down, adjusting oxygen settings, or pushing the start button on an infusion pump;
• blood sugar checks and taking vital signs;
• applying ointments of any kind.

Nebulizers. Adding a tube of medicine to a nebulizer is medication administration, not medication assistance, under the PSSA rules. TDMHSAS explains: "This would be considered medication administration because the personal support worker would be determining dosage by inserting a tube of medicine into a machine for use." (PSSA slide 23)

For certified staff, ask first. Against each list TDMHSAS adds: "Please consult with the Medication Administration Certification Program to determine if these services are allowed for certified personnel according to the new statue for PSSAs under TDMHSAS Licensure." (PSSA slides 25-27) By our reading, a task on the list stays off limits for certified staff too until the program confirms it, and you keep that answer in writing.

CareRulebook’s manual restates the full not-allowed list in plain words in Policy 2.1, with what a worker says when a client or family asks for one of these tasks.

Public Chapter 730 (2024) amended T.C.A. 68-1-904 and took effect when it became law: "This act takes effect upon becoming a law, the public welfare requiring it." (section 4) It does four things for PSSAs:

• Opens DDA’s training to PSSA staff. The training may be given "to unlicensed individuals employed by personal support service agencies (PSSAs) licensed under title 33" (section 1).
• Lets certified employees administer. "An unlicensed person who is employed by a personal support service agency (PSSA) licensed under title 33 may administer medications to an individual who is incapable of self-administration in the individual’s place of residence after the unlicensed person satisfactorily completes a competency-based training program approved by the department of mental health and substance abuse services." (section 2)
• Sets a hard limit. Certified staff "shall not administer intravenous, intramuscular, or certain subcutaneous injectable medications, as defined by rule" (section 3).
• Leaves the training rules to DDA, and exempts certified staff from nurse licensing. "The department of intellectual and developmental disabilities, in consultation with the board of nursing, shall promulgate rules, including emergency rules, to provide for competency-based training, education, and appropriate monitoring of the unlicensed personnel covered by this subsection (c)", and "the unlicensed personnel are exempt from the licensing requirements contained in and rules promulgated pursuant to title 63, chapter 7, part 1" (section 3).

Three conditions, read together. By our reading of section 2, certified administration needs all three: an employee of the PSSA, a client who is incapable of self-administration (the rules define self-administration as taking medication "without assistance from another person", 0940-05-38-.01(10)), and the client’s place of residence. A client who can take their own medication with reminders stays with medication assistance.

Employees, not subcontractors or family. The act says "employed by". DDA’s sample policy adds: "Administration of medications by natural supports or volunteers is not covered under the exemption since they are not employed by a Department of Disability and Aging (DDA) provider." (DDA sample, section 3). Whether a subcontracted worker counts as employed here is not answered in the sources we saved. By our reading, use employees for medication administration until TDMHSAS says otherwise.

Children. DDA’s sample also says "Administration of medications to persons under the age of 18 is not covered under the exemption." (DDA sample, section 3). The PSSA client definition sets no age limit (0940-05-38-.01(2)), so if you serve children, by our reading keep them on medication assistance.

• No grace period. DDA’s presentation for agencies says: "There is no grace period for administering medications!" (DDA presentation, slide 10) Staff may still take a test-out or class up to 30 days after expiry, but may not administer in the meantime (DDA agency guidelines).
• Working before certification. DDA notes staff can start work before medication administration training, provided they do not administer medication. (DDA, Medication Administration)
• Keeping it. TDMHSAS says: "Any caregivers who become medication administration certified must maintain their certification and follow the regulations surrounding this allowance to continue performing such services." (PSSA slide 22)

TDMHSAS’s notice to PSSAs says agencies "should" do four things beyond signing caregivers up (PSSA slide 22):

1. "Notify their assigned TDMHSAS Licensure Surveyor that they intend to seek caregiver certification."
2. Keep a copy of each worker’s certification in their personnel file for TDMHSAS review.
3. "Develop and implement a Medication Safety Policy." TDMHSAS can provide DDA’s sample, which it calls "a standardized medication administration policy consistent with the program rules".
4. Make sure enrolled staff read and understand the purpose of the certification and what is expected of them before the class.

These are TDMHSAS’s requests, not rule text: the PSSA chapter has no medication administration rule. TDMHSAS also says its intended rules "are not necessary on the front end of caregiver ability to receive this certification" (PSSA slide 22), so you can certify staff now. By our reading, an agency that follows all four requests, in writing, is in the strongest position when the rules arrive.

DDA’s Chapter 0465-01-03, Administration of Medication by Unlicensed Personnel, runs the certification program. It was written in 2015 for DDA’s own providers: it defines a provider agency as a "private non-profit or for-profit entity under agreement/contract with the Department to provide services to individuals with intellectual and/or developmental disabilities" (0465-01-03-.02(15)). Public Chapter 730 came later, and TDMHSAS has not said which of DDA’s agency duties it expects PSSAs to follow. By our reading, the parts that describe the certification itself apply to anyone certified through DDA’s classes, and the agency duties are a sound model until TDMHSAS makes its own rules.

For comparison: DDA’s own PSSA rule. DDA’s own PSSA chapter, for agencies serving mainly people with an intellectual or developmental disability, has a medication rule: consider the person’s ability when supervising self-administration, prescriptions taken only by the person they are prescribed for, locked storage, disposal of discontinued or badly labeled medication, and reporting errors and reactions to the prescriber. TDMHSAS’s chapter has no such rule. (0465-02-17-.06(1))

DDA’s sample covers medication prohibitions, security, program requirements, storage and labeling, MAR editing, refusals, the MAR, controlled substances, variances, disposal, family visits and self-administration. It is written for DDA providers; by our reading it needs adapting to home care. (DDA sample, revised 10/15/25) Some of it assumes staff control a medication room in a home the provider runs. In a client’s own home the medications belong to the client, so a few parts need changing:

• Keys. The sample says "The certified staff assigned to administer medications will be responsible for the medication keys and will be the only person to have access to the medication storage area during their shift" (section 2). By our reading, a home care policy instead records where the client keeps medications and agrees locked storage with the client and family where others could reach them.
• Checking a new MAR. "Three different licensed/certified staff will edit MARs by comparing the current practitioner order to the MAR and initial prior to medication administration with new MAR." (section 5) Most home visits have one staff member, so by our reading two checkers (the certified worker and a supervisor, nurse or second certified worker) is a workable home care version. Ask TDMHSAS if you want certainty.
• Timing. "Medications must be administered within one (1) hour before or one (1) hour after assigned time." (section 7) Visit schedules have to fit around the doses, which affects staffing.
• Refusals. "Medications refused by persons following 3 attempts must be documented, monitored and reported accordingly." (section 6) Decide who the worker tells before leaving the home.
• Controlled substances. DDA’s sample policy keeps controlled substances double locked and counted at the beginning and end of each shift by two staff, one of them certified. (section 8) With one worker per visit there is rarely a second person; by our reading, count at the start and end of each visit and record when no witness was available.

CareRulebook’s manual makes these adaptations in Policy 2.12, offered only if you choose certified administration, and says plainly that, beyond TDMHSAS’s four requests, its contents are the agency’s own practice until TDMHSAS files rules.

• Theft of medication is reportable. TDMHSAS’s list of reportable incidents includes "Theft by staff of service recipient’s personal items", naming medication among the items (TDMHSAS Incident Reporting Requirements). Its current deadline is the close of the next business day (TDMHSAS).
• Medical problems go in the record. The client record documents medical problems, illnesses and treatments, accidents, adverse incidents and follow-up while the client receives services (0940-05-38-.09(1)(k)). By our reading that includes medication errors and reactions.
• An unsafe certified worker. Take them off medication at once; DDA’s rules have the agency recommend that DDA end their authority (0465-01-03-.08(1)).

Incident reporting in full is in the guide (abuse and incident reporting).