Sample Policy: Distribution of Drugs, Vitamins, Nutritional Supplements or Other Ingestible Substances
The following article is excerpted from: Lopiano, D.A. and Zotos, C. (Publication 2013) The Athletics Director’s Handbook: A Comprehensive Practical Guide to the Management of Scholastic and Intercollegiate Athletics Programs. Champaign, IL: Human Kinetics.
One of the most difficult oversight areas for the athletics manager involves the administration, ordering and storage of over-the-counter and prescription drugs and nutritional supplements by athletics training personnel. Even written policies issued by state licensing authorities governing what NATA board certified and state licensed athletics trainers are often unclear regarding required conditions. In general, policies should always require that no staff member other than athletics trainers give any of these substances to student-athletes and only when specifically authorized by a physician and documentation of such administration should always be maintained.
The athletics manager should consult with the licensing authority in his or her respective state to insure that the following policy meets licensing standards and restrictions.
1.0 No Distribution of any Substance by Non-Medical Personnel. Non-medical employees (all staff other than state licensed athletics trainers, licensed campus health center personnel, consulting physicians, etc.) are strictly prohibited, under all circumstances, from dispensing or recommending for the improvement of health or performance, any drug, medication, vitamin, nutritional ergogenic aid or other ingestible solid or liquid supplement purported to improve health or performance to any student-athlete. Any distribution of such substances by such non-medical personnel is grounds for immediate termination of employment. Any student-athlete with a medical problem should be referred to the athletics training staff or Student Health Center.
1.1 Strength and Conditioning Coaches. Strength and conditioning coaches who are C.S.C.S certified may provide nutritional information or advice to student-athletes regarding whether nutritional supplements contain recreational or performance enhancing substances banned by the NCAA or national sport governing bodies but may not distribute drugs, vitamin, nutritional supplements or other ingestible substances to student-athletes.
1.2.1 Nutritional Supplement For purposes of this policy, a ‘nutritional supplement’ is defined as any foodstuff or dietary procedure that either improves or is thought to improve physical performance. Examples include vitamins, minerals, amino acids, special proteins, herb extracts, enzyme complexes, and other nutritional compounds marketed for specific athletic groups or to the general public.
1.2.2 Drug. A “drug” includes over-the-counter (“OTC”) drugs and prescribed drugs, even if prescribed by a medical physician. It is not the responsibility of a non-medical employee to dispense these substances.
1.2.3 Banned Substance. The NCAA prohibits use of the following classes of drugs: (a) stimulants, (b) anabolic agents; (c) alcohol and beta blockers (banned for rifle only), (d) diuretics and other masking agents, (e) street drugs, (f) peptide hormones and analogues, (g) anti-estrogens, and (h) beta-2 agonists. Any substance related to these classes is also banned.
1.3 Fluid Intake. Nothing in this policy shall be interpreted as not permitting coaches to promote the intake of water, Gatorade or other fluid replenishments provided by the athletics training staff. Coaches shall not withhold or limit fluid intake during any practice session. Regular breaks for fluid intake are desirable at intervals of a maximum of 30 minutes.
1.4 Supplement Verification. The production of nutritional supplements is not government regulated. These supplements often contain substances not noted on the label and may contain banned substances. Student-athletes are required to declare all nutritional supplements and drugs they are taken as part of the pre-participation medical history. If there is any question about the formulation of any supplement, the Head Athletics Trainer is responsible for sending such substance to Drug Free Sport Center for verification.
2.0 Communication of Policy to Student-Athletes. At the beginning of each academic year, the senior staff member responsible for overseeing the respective sport program and the Head Athletics Trainer shall review this policy with all student-athletes.
3.0 Distribution of Drugs and Other Substances by Certified Athletics Trainers
3.1 General. A state licensed and NATA board certified athletics trainer and licensed health personnel employed by the Student Health Center are authorized to administer drugs and other substances according to the policies in this section. “Administered” is defined as direct application or provision of a single dose of a prescription drug by a certified athletics trainer, nurse or physician which has been prescribed by a team or other physician and when such administration has been authorized in writing by that prescribing physician. “Dispensed” refers the prescribing and ordering of a drug by a physician from a pharmacy or other supplier.
3.2 Prescription Drugs. Prescription drugs may only be dispensed (prescribed and ordered) by a licensed physician according to state, federal and DEA laws. No physician can delegate responsibility for diagnosis and dispensing/prescribing drugs to a certified athletics trainer. The Team Physician is expected to convey at the time of initial examination and issuance of any prescription information about the drug, indications for use, side effects, and interactions with other drugs or foods.
3.2.1 Administration by an Athletics Trainer. Any prescription drug administered by a NATA board certified athletics trainer requires the written authorization of the Team Physician (or other consulting physician), such documentation to be kept on file in the athletics training facility. Pursuant to such physician’s written authorization, a certified athletics trainer may administer direct application of single doses of a prescription drug according to the following procedures:
- a written record of the drug, dosage, date administered and by whom must be recorded;
- at the time of administration, the student-athlete must be provided with, orally and in writing, information about the drug, indications for use, side effects, and interactions with other drugs or foods; and
- the athletics trainer administering the dose shall assess the student-athlete’s understanding of compliance with the medication regimen.
3.3 Over-the-Counter (OTC) Medications. Any OTC medication administered by a certified athletics trainer requires the written authorization of the Team Physician (or other consulting physician) for a specific student-athlete’s condition or via “standing orders” for common health conditions for which OTC medications are appropriate. Such documentation shall be kept on file in the athletics training facility. Pursuant to such orders, OTC medications conforming to specified dosages may be administered by certified athletics trainers according to the following procedures:
- a written record of the athlete’s name, indications for use, the medication, dosage, frequency and date dispensed must be recorded;
- the certified athletics trainer administering the medication is expected to convey orally and in writing, information about the drug, indications for use, side effects, and interactions with other drugs or foods;
- the certified trainer administering the drug shall assess the athlete’s understanding of compliance with the medication regimen;
- if subsequent student-athlete self-administered dosages are specified, such medication shall be provided in a unit dose package or in an envelope or dispensing container marked with the athlete’s name, the dispensing date, the name of the drug, quantity and directions for use; and
- minors shall not be provided with over-the-counter medications without parental consent, such consent and administration being recorded and that record kept on file.
3.4 Iron, Calcium and Vitamin Supplements. Iron, calcium and vitamin supplements according to recommended daily allowances (RDA) or in therapeutic dosages may be administered by certified athletics trainers only when documented by appropriate clinical evaluation and recommended by the Team Physician or other consulting specialist.
3.5 Student Athletics Trainers. Student athletics trainers are not permitted to distribute or administer prescription drugs under any circumstances but may distribute or administer over-the-counter drugs and iron, calcium or vitamins under the direct supervision and in the presence of a certified athletics trainer.
4.0 Drug Purchase and Storage Procedures. At times the athletics training room serves as the office of a Team Physician and the Team Physician directs that specific prescription and OTC medications be stocked and available for his/her use. The athletics training facility and personnel shall comply with all state and federal laws regarding dispensing medication (including display of certificates or documentation on file) prescribed by a physician or other prescription medication on hand as directed by the team physician. Any medication administered from athletics training room stores shall be recorded in a log and the physician’s script and diagnosis authorizing administration must be kept on file in the training room.
4.1 Labeling and Inspection. State, federal and DEA regulations regarding packaging, labeling, record keeping and storage of prescribed medications in the athletics training facility must be followed. All drug stocks shall be regularly inspected for expiration dates and those expired drugs shall be appropriate discarded with such disposal logged by date and disposal process.
4.2 Storage. Drugs must be stored in a metal cabinet with tamper proof locks that is environmentally controlled (dry temperature between 59-86 degrees F) in a location that is under the direct supervision of certified athletic trainers. In addition, the athletics training facility must be locked whenever the facility is not under the direct supervision of certified athletic trainers. Medical kits containing prescription or OTC drugs must be stored in a locked cabinet or closet when not being carried by a certified athletics trainer assigned to cover a practice or game.
4.3 Inventory. At least once each month, the Head Athletics Trainer and a designated Assistant Athletics Director shall perform a random audit of the prescription and OTC drug inventory in the athletics training room to insure accurate reconciliation of drug issuance logs, physician’s written authorization, stored drugs and purchase orders.
4.4 Purchase of Drugs. Only the Team Physician or consulting specialty physicians shall authorize, in writing, the prescription and/or OTC drugs to be purchased by the athletics training staff and stored in the athletics training facility or in medical kits traveling with a team. Such written authorization (and copy of the physician’s license if required) shall be attached to any purchase order utilized to obtain such drugs. The Associate Athletics Director for Business Affairs shall confirm such documentation via telephone with the authorizing physician(s) prior to approving the purchase order.
5.0 Research Protocols. Student-athletes are permitted to voluntarily participate in research protocols involving the distribution of nutritional supplements or other ergogenic aids according to institutional rules and regulations governing research with human subjects and the following additional procedures:
a. Approval by Medical Physician. The protocol must be reviewed and approved by the Team Physician, athletics trainers and consulting specialists.
b. Full Disclosure. The student-athlete and the head coach shall receive a copy of the protocol together with an oral explanation of the purpose and risks involved in the procedures as presented by the sports medicine staff.
c. Distribution and Administration of Substances. The student-athlete and the coaching staff shall be informed that no coach is permitted to distribute/administer any substance or supplement and that such substance shall be administered by certified athletics trainers or student-athletics trainers under the direct supervision of the credentialed athletic trainer.
d. Record Keeping. Such protocols shall be administered under strict rules of recordkeeping according to the requirements of the institutionally approved research protocol.
e. Voluntary Participation. The student athlete shall be given the opportunity to ask questions and shall be informed in writing and orally that participation in the protocol involving the ingestion of any substance is strictly voluntary. The student-athlete shall indicate that all procedures were followed and that his or her decision to participate was on a voluntary basis by signing a written consent statement to this effect. In the event the student athlete is under eighteen years of age, the signature of his or her parents is also required.
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