DRAFT - Competency-Based Training and Assessment Policy

Illinois Department of Human Services

Division of Developmental Disabilities

Information Bulletin

DD.25.XXX

Purpose

Rule 116 outlines the requirements for an Authorized Direct Support Professional (ADSP) to administer medication to persons living in settings governed by Rule 116. Included in those requirements is a competency-based training and assessment (CBTA); this Information Bulletin (IB) outlines the CBTA process.

Background

Effective January 1, 2025, Public Act 103-0890 went into effect and amends the administrative act. This information is the interpretive guidance until Rule 116 is amended to include the legislative changes.

Definitions

  • Competency-Based Training and Assessment (CBTA): The process in which an ADSP is trained and assessed by a nurse trainer (RNT) to develop and determine if they have the necessary skills to be approved to safely administer medications and other delegated supports to individuals receiving services under the purview of Rule 116 (CILA, ICILA, CDS, CGH, ICF/DD with 16 individuals or less). 
  • Continuing Medication Administration Training (CMAT): The process in which an RN Trainer trains and communicates pertinent information about medications, their side effects, and how to administer them. CMATs occur after an ADSP has successfully completed an in-person CBTA. CMATs can be done in-person, virtually by video, or over the phone.
  • Medication Pass: For purposes of this IB, a medication pass is defined as administering medication in a Rule 116 setting. Medication administration during the medication pass should happen under typical circumstances in the setting.
  • Medication Routes: Medication is administered in various routes. The most common is orally (by mouth). Other routes include, but are not limited to, topical, inhalants, ear drops and eye drops. These are required to be reviewed during the 8-hour medication training class.  
  • Registered Nurse Trainer (RN Trainer or RNT): An RN Trainer is a registered nurse who has completed the requirements to be a nurse trainer within the Division of Developmental Disabilities (DDD). Only an RN Trainer can train ADSPs or be on-call for ADSPs regarding medication administration questions.
  • Professional Responsibility of the RN Trainer: RN Trainers are ultimately responsible for determining if the task of medication administration can be delegated to an ADSP. The process in this IB is the minimum standard. RN Trainers should continue additional training as they see necessary. RN Trainers have a professional responsibility to continue to train and monitor ADSPs capacity to safely administer medications and other delegated tasks.

CBTA Process

During the initial medication administration training class, the DSPs should be given a thorough overview of how to administer medication through all routes. During the 8-hour medication class there should be practice time for return demonstration of the various medication routes. This should be documented in the skills checklist. This is the foundation of the CBTA process. DSPs must demonstrate proficiency in passing medications as determined by the nurse-trainer. DSPs demonstrate proficiency by completing the following:

  1. If the DSP has had no prior experience passing medications with that organization, the RN Trainer must observe, in person, the DSP complete a medication pass. It should be for the home in which the DSP will be working during a typical medication pass.  The requirement is for the RN Trainer to have the opportunity to evaluate, and potentially further train, the DSP's ability to manage medications during a typical day.
  2. The in-person observation must be documented on the CBTA form.
  3. The Medication Administration Record (MAR) used for the CBTA for each person in the home must be attached to the CBTA form and produced during a Rule 116 survey.
  4. It is required for the RN Trainer to observe a medication pass when the majority of the home is receiving their medications.
    1. If the in-person CBTA is completed with less than 3 people, then they would need to receive an additional CBTA to pass medications in a home with more than 3 individuals.

Administering Medications to New Individuals

When an ADSP is scheduled to administer medications to an individual served that was not involved in the ADSP's in-person CBTA process, the RN Trainer must have a process in place to ensure that the ADSP has the competency to administer that medication to that person. This is called Continuing Medication Administration Training (CMAT). The process must include the following: 

  1. The organization must have a policy in place that the RN Trainer uses to train the ADSP. After the ADSP has an initial in-person CBTA, the RN Trainer is responsible for providing CMAT for the medications the individual is prescribed. CMATs can be done in person, virtually via video, or by phone (recommended only for simple medication changes). The RN Trainer's professional judgement determines if the training after the in-person CBTA is in-person, virtually, or by phone.
  2. The CMAT that occurs must be documented. The following must be included in the documentation:
    1. Mode of training (in-person, video, or by phone)
    2. Date and time of the CMAT
    3. It must demonstrate that the RN Trainer has reviewed the medication pass process and the individual's medications with the ADSP.
    4. It must demonstrate that the RN Trainer has reviewed general side effects of medications with the ADSP and communicates the need to report anything unusual to the RN Trainer.

This process should be documented on a CMAT form. This form will be released in conjunction with the finalization of the IB.

Administering a New Medication or a Change to an Existing Medication

When an ADSP is scheduled to administer a new medication or there is a change to an existing medication (for example: dosage, route, or frequency) the RN Trainer must have a process in place (and documented in policy) to ensure that the ADSP has the training and competency to administer that medication to that individual. This includes documenting the following: 

  1. Communication with the ADSP that explains the medication and/or any changes to the medication and how the individual may react to this medication and its potential side effects.
  2. Date and time of communication.
  3. This should be documented on a medication change form or the appropriate section in the provider's electronic medication administration record (eMAR).

Standards for Virtual CMAT

The standards for an agency utilizing a virtual CMAT are as follows:

  1. The provider must have a written policy governing when it is appropriate to conduct a CMAT.
  2. During the 8-hour medication class there must the opportunity for the ADSPs to demonstrate how to administer medications through the various routes. This should be documented on the skills checklist: Section 8 Check Lists
  3. RN Trainer is required to document on CMAT paperwork how the CMAT was conducted (in-person, virtually, or via phone).
  4. The following virtual CMAT standards are required:
    1. The platform used must be secure to ensure confidentiality (the platform must be explicitly identified in the agency's policy).
    2. The ADSP administering the medication cannot also be holding the device/camera if a medication pass is being observed. There must be an additional staff (it is not required to be a DSP) member holding the device/camera or a web camera (or some comparable device) that allows hands free videoing.
    3. Ensure that the camera angle shows hand hygiene, medication preparation and administration.
  5. The delegation of the following must always be trained in-person with a CBTA: insulin or other injectable medications approved under Rule 116, eye drops (unless it is saline eye drops for lubrication), inhalers that are scheduled on a regular basis, g-tubes, vaginal/rectal suppositories, or additional delegation tasks that the RN Trainer determines can only be done safely with in-person training.
  6. If after providing a CMAT, the RN Trainer does not feel confident that the ADSP can administer the medication safely, an additional in-person CBTA should be performed.

Contact:

Please email comments on this DRAFT Information Bulletin to DHS.DDDComments@illinois.gov. Please include the title of the DRAFT IB in the subject line of the email.

Effective Date:

This bulletin is effective upon posting as final.

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