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Model Policy: Supplements, Prescriptions and Over-the-Counter Drugs

Athletic departments often impose strict policies regarding the use of recreational or performance enhancing drugs by student-athletes and often have extensive drug testing programs designed to detect and prevent such use.  However, many departments do not have policies in place that address the issuance of vitamins, supplements and over-the-counter drugs by coaches, trainers or other department employees.  These policies are particularly important given the fact that vitamins and other supplements are a relatively unregulated industry in the United States.  Occasionally, some supplements to contain substances that may be prohibited or classified as performance-enhancing drugs.  It is also important for institutions to be very clear about the fact that prescription drugs may only be dispensed by certified doctors.  There is also an issue about the appearance of impropriety which may occur when coaches or other non-medical personnel are observed dispensing pills or other substances to athletes.  All of these issues should be clearly addressed by institutional policy.
The following policy and procedure is a sample.  Do not use verbatim.  Follow instructions to insert information applicable to your institution and then submit to your legal counsel for review to be sure all elements conform to institutional policy and applicable local, state and federal laws.

(Name of Institution)
3.0  Policies and Procedures Regarding the Distribution of Drugs, Vitamins, Nutritional Supplements or Other Ingestible Substances

3.1    General.  Non-medical employees 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.  Further, non-medical employees are prohibited from distributing to any student-athlete any prescription or over-the-counter medicines, including aspirins, cold medicines, etc.  Any distribution of such substances is grounds for immediate termination of employment.  Any student-athlete with a medical problem should be referred to the athletic trainer, school nurse or health center.

3.1.1    Definitions.  For purposes of this policy, a ‘nutritional supplement’ is defined as any foodstuff or dietary product 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.  This policy also includes non-medical employee distribution of over-the-counter 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.

3.1.2    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 athletic 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.

3.1.3    Communication of Policy to Student-Athletes.  At the beginning of each academic year, the Athletics Director shall review this policy with all student-athletes. 

3.2    Distribution of Drugs and Other Substances by Credential Athletic Trainers.  

3.2.1    General.  A credentialed athletic trainer is authorized to distribute drugs and other substances according to the following policies:

a.     Prescription Drugs.  Prescription drugs under the direction and supervision of the prescribing physician according to the following procedures:  (a) drugs must be stored in by tamper proof locks in a metal cabinet that is environmentally controlled (dry temperature between 59-86 degrees F) in a location under the direct supervision of credentialed athletic trainers, (2) a written record of the drug, dosage and date dispensed must be recorded, (3) the trainer is expected to convey orally or in writing, information about the drug, indications for use, side effects, and interactions with other drugs or foods and (4) the trainer shall assess the athlete’s understanding of compliance with the medication regimen.  The athletic training facility shall display a Drug Enforcement Agency certificate identifying the physician responsible for the prescription medication on hand.  Note:  The department's drug policy should require immediate notification of the head athletics trainer whenever a drug is prescribed in order to avoid conflict with prohibited substances.

b.    Over-the-Counter Medications.  Over-the-counter medications according to the following procedures:  (a) medications must be stored in a locked cabinet in a location under the direct supervision of credentialed athletic trainers, (2) a written record of the athlete’s name, indications for use, the medication, dosage, frequency and date dispensed must be recorded, (3) the trainer is expected to convey orally or in writing, information about the drug, indications for use, side effects, and interactions with other drugs or foods, (4) the trainer shall assess the athlete’s understanding of compliance with the medication regimen and (5) the 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.  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.

c.    Iron, Calcium and Vitamin Supplements.  Iron, calcium and vitamin supplements according to recommended daily allowances (RDA) or in therapeutic dosages only when documented by appropriate clinical evaluation and recommended by the team physician or other consulting specialist. 

d.    Student Athletic Trainers.  Student athletic 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 of a credentialed athletic trainer.

3.2.2    Research Protocols.  Student-athletes are permitted to voluntarily participate in research protocols involving the distribution of nutritional supplements or other ergogenic aids according to the following procedures:

a.    Approval by Sports Medicine Physician.  The protocol must be reviewed and approved by the sports medicine staff and consulting specialists.

b.    Full Disclosure.  The student-athlete 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 shall be informed that no coach is permitted to distribute/administer any substance or supplement and that such substances shall be administered by credentialed athletic trainers or student-athletic 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 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 3.2.2 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 18 years of age, the signature of his or her parents is also required.

-- by Donna A. Lopiano, Ph.D., President, Sports Management Resources