Formulary and Pharmacy Governance
The foundation of GDC's medication management system is the Statewide Pharmacy and Therapeutics (P&T) Committee, established under SOP 507.04.78. The Committee "will advise the Statewide Medical Director on the status of the Pharmacy and Therapeutics Program" and is responsible for identifying and recommending medications to be added or removed from the GDC formulary—including over-the-counter (OTC) drugs. The formulary is defined as "a written list of the medications authorized for use in GDC." Health-related commissary items, including OTC medications available for offender purchase, are reviewed and approved annually by this same Committee under SOP 507.04.51.
At the executive level, SOP 507.01.09 places the Executive Medical Management Committee (EMMC) in an oversight role that includes "oversight of the Pharmacy and Therapeutics and the Continuous Quality Improvement Committee activities." The EMMC meets monthly and includes pharmacist representation from contracted vendors.
Prescribing and Ordering Authority
All treatment orders must come from personnel authorized by law. SOP 507.04.30 (Direct Orders) states: "All treatment orders generated by an advanced clinical provider will be documented in the physician's orders section of the health record. The order will include the date and time the order was written." An exception exists for non-prescription OTC medications given to an offender at the time of a clinical encounter, which are documented in progress notes rather than the physician's orders section.
Under SOP 507.04.30, a physician's assistant may order prescription medications only if the supervising physician has delegated that authority in an approved job description. A nurse practitioner may write orders pursuant to a written protocol jointly signed by the NP and physician—those orders do not require physician countersignature, but the pharmacist must receive copies of all advanced clinical provider protocols for verification of physician approval. Verbal or telephone orders must be signed by the clinician within five days.
SOP 507.03.08 (Nurse Practitioner or Physician's Assistant Practice) elaborates on prescribing limits, defining that NPs and PAs may "Order" drugs under physician delegation, but that ordering "shall not be construed to be prescribing, which act can only be performed by the physician, nor shall Ordering of a Drug be construed to authorize the issuance of a written prescription."
Nursing protocols, governed by SOP 507.04.31, explicitly state that "Nursing Protocols will not contain any directions regarding utilization of Legend (prescription) Medications except for those covering emergency, life-threatening situations," and that nurses initiating emergency drug protocols must be ACLS certified and have an order from an advanced clinical provider. Standing orders are prohibited in all GDC facilities.
Order Transcription
SOP 507.04.32 requires that all medication orders be transcribed by a registered or licensed practical nurse. Routine medication orders must be transcribed within eight hours; STAT and "Now" orders must be transcribed immediately. Inpatient areas at Augusta State Medical Prison (ASMP) and infirmaries must transcribe routine orders within four hours. Each transcribed order must be signed, dated, and timed. STAT and "Now" orders require corresponding documentation in both the progress notes and the Medication Administration Record (MAR).
Administration Methods: DOT and SAM
GDC uses two primary administration models. Directly Observed Therapy (DOT) is defined under SOP 507.04.45 as "a method of drug administration in which a healthcare professional/officer watches as an offender takes each dose of a medication." The Self-Administration of Medication (SAM) program "permits responsible offenders to carry and administer their own medications."
SOP 507.04.07 (Scope of Treatment Services) states broadly that "all offenders will receive appropriate medication therapy and therapeutic diets as ordered by the provider," establishing medication access as a baseline right across the entire custody continuum.
For offenders in restrictive housing, SOP 507.04.33 requires that upon placement the licensed health care provider review the record for DOT and SAM medications and arrange for DOT medications to be delivered "at the next scheduled medication administration."
Who May Administer Medications
SOP 507.03.13 (Medication Administration Training) specifies that "health care or correctional staff who administer or deliver medication to offenders must be permitted by state law to do so." Health care staff include Certified Medical Assistants, CNAs, EMTs, Health Services Technicians, LPNs, pharmacy technicians, and RNs. All correctional officers receive medication administration training during Basic Correctional Officers Training (BCOT) and must complete at least annual in-service training thereafter. At facilities where health care staff are on-site seven days a week for at least two shifts, qualified health care professionals—not correctional officers—must administer medications during those shifts.
Staff administering medications are trained in security, accountability, common side effects, documentation, and "hoarding of medications, selling of drugs, overdoses, and adherence to therapeutic regimens" (SOP 507.03.13).
Medication Nonadherence
SOP 507.04.45 establishes tiered thresholds for what constitutes nonadherence:
- Routine DOT medications: Missing four (4) doses in a seven (7) day period.
- High Risk Medications (insulin, antiretrovirals, Hepatitis C, anticoagulants, TB medications): Nonadherent after missing one (1) or more doses within a seven-day period.
- High Risk mental health medications (mood stabilizers, antipsychotics, antidepressants) for offenders classified Mental Health Level 3 or 4: Nonadherent after missing 25% or six (6) consecutive doses of TID medications, four (4) consecutive doses of BID medications, or two (2) doses of QD medications within a seven-day period.
When high-risk medication nonadherence is identified, the designated medication nurse must provide "immediate notification to security to escort these offenders to the Medical Section for medication administration or refusal and counseling." Documentation must occur on both the MAR and the Medication Nonadherence Counseling Form, with an immediate referral to a clinician. The medication nurse must review MARs for nonadherence at least once per calendar week.
For routine medications, a counseling session must be scheduled within fifteen (15) days. Offenders on SAM must bring medications to chronic illness clinic visits for compliance checks.
Correctional staff are required to check for contraband medications during periodic shakedowns and report findings to medical staff; confiscated medications are returned to health care staff unless needed for disciplinary or legal purposes (SOP 507.04.45).
Right to Refuse and Involuntary Administration
SOP 507.04.86 (Right to Refuse Treatment) grants offenders the right to refuse medications, but establishes specific documentation requirements: a signed refusal form, notation on the MAR, and for serious medical conditions, clinician counseling documented in progress notes. Offenders may not sign a blanket refusal; refusal must be case-by-case. When a refusing offender will not sign the form, the clinician completes it and writes "patient refuses to sign," with two witnesses required.
For psychotropic medications specifically, SOP 508.26 (Involuntary Medication Administration) establishes a due process framework. GDC "seek[s] voluntary participation from offenders on the mental health caseload for whom psychotropic medication has been prescribed." Involuntary administration is permitted under two conditions: (1) a psychiatric emergency in which the offender presents imminent risk of harm to self or others, or (2) following a formal Involuntary Medication Due Process Hearing. The hearing committee consists of three members—a deputy warden of care and treatment or designee, a professional mental health staff member, and a medical staff member—none of whom may have been directly involved in recent treatment of the offender. An offender advocate, who cannot be the offender's assigned counselor, is assigned to assist the offender.
Psychotropic Medications
SOP 508.24 (Psychotropic Medication Use Management) requires that psychotropic medications be prescribed only when medically indicated, with informed consent documented in a language understood by the offender. A psychiatrist or APRN must complete an Initial Psychiatric Evaluation and establish a DSM-consistent diagnosis before initiating psychotropic medications. Prescribing "will not be used for disciplinary purposes." All necessary screening tests must be ordered at or prior to initiation of therapy, and ongoing monitoring for clinical response and side effects is required.
Mental health facilities are required under SOP 508.11 to track psychotropic medication non-adherence statistics as a mandatory quarterly CQI topic, alongside emergency forced medications and involuntary medication data.
Medication Errors
SOP 507.04.46 defines a medication error as "a dose of medication that deviates from the physician's order as written in the patient's chart or from standard policy and procedure" that "actually reach[es] the patient." Ten error categories are defined: omission, unauthorized drug, wrong dose, wrong route, wrong rate, wrong dosage form, wrong time, wrong preparation of a dose, incorrect administration technique, and pharmacy filling error.
When an error is discovered, an MD, NP, or PA must be notified immediately. An incident/error report is completed and sent to the nursing and medical authority. Incident reports are maintained in a confidential file in the medical unit and are "not part of the offender's health record." Any Serious Adverse Event (defined as resulting in hospitalization, disability, or death) must be reported to the Statewide Medical Director, Statewide Clinical Services Supervisor, the facility Warden, and the Department's General Counsel within twenty-four hours.
SOP 507.04.76 (Incident Reporting) reinforces that medication adverse action reports are reviewed by the P&T Committee and through the CQI process to assess trends and make corrective recommendations.
Medication Continuity During Transfers and Release
SOP 507.04.25 (Health Screening-Offender Transfers) requires that a licensed health care provider review an offender's record before any intra-system transfer, including review of "current medications." Current medications must be transferred to the receiving facility with the medical records. The older SOP 215.16 separately specifies that inmates transferring to transitional centers must be provided with at least a 30-day supply of properly labeled and packaged medications.
For mental health offenders being released, SOP 508.35 requires that a final psychiatric evaluation be scheduled as close as possible to the actual release date, with the psychiatrist/APRN prescribing at least a 30-day supply of blister-packed discharge medications.
OTC Medications and Commissary
SOP 507.04.51 allows offenders to purchase approved OTC medications from the commissary or access them through sick call. Indigent offenders "will be offered OTC medications as indicated without regard to ability to pay." Offenders classified as Mental Health Level III or above may not purchase OTC medications from the commissary. Possession is limited to one full container and one partial container of each item at any time.
Medication Copays
Under SOP 507.04.05, each offender is charged a $5.00 copay per co-pay eligible medication. Deductions are not made when an offender's account balance is $10.00 or less. Chronic care visits and medical emergencies are exempt from visit copays, but medication copays are addressed separately. Transitional Center offenders are charged a $10.00 copay per SOP 507.04.02.
Staff Training
SOP 507.03.09 (Orientation Training for Health Care Staff) lists medication administration as a required component of health care staff orientation. SOP 507.03.13 requires that training be approved and reviewed annually by the responsible physician or designee and the facility administrator, with documentation maintained in each employee's training record.