Section 01
Purpose
This policy sets out We Are Care’s approach to medication management as a workforce supplier to the social care sector. We do not operate our own care settings and we are not a CQC-registered direct provider. The medication framework — including policy, storage, administration protocols, and audit — sits with the client provider where our carers are placed. This policy describes our responsibilities for ensuring the carers we supply are competent, trained, and able to operate safely within each client’s framework.
Section 02
Scope
This policy applies to all care workers, healthcare assistants, and nurses employed by We Are Care who may be required to administer or support medication during shifts at client provider settings.
Section 03
Legal and regulatory framework
Although We Are Care is not the CQC-registered entity in the settings where our carers are placed, we operate to standards consistent with:
- Medicines Act 1968
- Misuse of Drugs Act 1971 and Misuse of Drugs (Safe Custody) Regulations 1973
- Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, particularly Regulation 12 (Safe Care and Treatment)
- NICE Guidelines on Medicines Optimisation
- Care Quality Commission (CQC) Fundamental Standards
- The Controlled Drugs (Supervision of Management and Use) Regulations 2013
Section 04
Key principles
Our approach is built on:
- Carer competence. Only carers we have assessed as competent in medication administration will be placed into shifts where that responsibility is required by the client.
- Client framework first. Carers follow the medication policy and procedures of the client provider where they are placed. We do not override or substitute the client’s framework.
- Dual reporting. Any medication concerns, errors, or adverse reactions are reported to both the client’s on-shift senior or registered manager AND to We Are Care.
- Continuous training. Medication competence is refreshed periodically through mandatory training.
Section 05
Roles and responsibilities
We Are Care (the employer)
- Assess and verify each carer’s competence in medication administration before placement
- Provide medication-administration training during induction and refresh periodically
- Maintain training and competence records for each carer
- Ensure carers understand they must follow the client provider’s medication policy at the placement setting
- Provide a clear reporting channel for medication concerns through Vicky Welfare (Director · Clients) and, for safeguarding overlay, the DSL
Care workers, healthcare assistants, and nurses
- Follow the medication policy and procedures of the client provider where they are placed
- Administer medications only when authorised by the client provider and only within the scope of their role and training
- Apply the 5 Rights of Medication Administration: right person, right medication, right dose, right route, right time
- Maintain accurate records as required by the client provider’s framework (e.g. MAR sheets)
- Report any medication concerns, errors, or adverse reactions immediately to the client’s on-shift senior or registered manager, and to We Are Care
- Decline to administer medication where the request falls outside their training, scope of practice, or the client’s authorised framework
The client provider
The client provider is the CQC-registered entity (or equivalent) and is responsible for:
- The medication policy that applies in their setting
- Medication storage, including controlled drugs and refrigerated medications
- Prescription oversight and the Medication Administration Record (MAR) system
- Authorising which carers (including supplied carers) may administer medications and which categories
- Controlled drug protocols, including any requirement for two-staff witnessing
- Reporting medication errors to CQC where required
Section 06
Competence and training
Before any We Are Care carer is placed into a role involving medication administration, we will:
- Verify their qualifications and prior training
- Provide induction training covering safe medication practices, the 5 Rights, error reporting, and adverse-reaction recognition
- Assess practical competence
- Ensure the carer understands they must work within the client’s framework, not substitute their own
Training is refreshed annually or more frequently if required by client provider standards or regulatory change.
Section 07
Medication errors and adverse reactions
Any error or adverse reaction must be reported immediately:
- To the client provider’s on-shift senior or registered manager — for immediate clinical response and the client’s incident process
- To We Are Care — via the carer’s line of report or the safeguarding channel where the error has caused or risks harm
We Are Care will record the report, support the carer through any investigation by the client provider or CQC, and review whether further training or competence reassessment is required. Where a medication error is also a safeguarding concern, the safeguarding policy applies and the DSL is notified.
Section 08
Lone working and medication
Where carers administer medication in domiciliary or single-carer settings, the absence of a second staff witness (for controlled drugs or otherwise) is a client-framework matter — the client provider determines and authorises the protocol. We Are Care does not supply carers into roles where the client’s framework requires a second witness that the carer cannot reasonably be expected to provide alone.
Section 09
Confidentiality and records
All medication-related information about service users is handled in accordance with the client provider’s framework and UK data protection law (UK GDPR, DPA 2018). Carer training and competence records are held by We Are Care and reviewed periodically.
Section 10
Monitoring and review
This policy is reviewed monthly by the Baton Care Advisory Council on the first Thursday of each month, and revised in flight if there are material changes to UK legislation, CQC guidance, or our operating model. Carer competence is monitored continuously through client provider feedback and We Are Care’s own assessment processes.
Section 11
Related policies
- Safeguarding Policy — applies where a medication concern overlaps with safeguarding
- Conduct and Capabilities Policy — applies where competence falls short
- Lone Working Policy — applies for single-carer placements
- Whistleblowing Policy — protects carers who raise concerns about client-provider medication practices
Section 12
Use of Baton
Where provider-approved, Baton may support prompts, records or follow-up tasks. It does not make medication decisions.