Hand Hygiene During Med Pass: One of the Most Cited Deficiencies Under 59A-36.008

Medication practices remain one of the most heavily scrutinized areas during assisted living surveys. Among those, hand hygiene during medication assistance is consistently cited—and often underestimated by staff and administrators alike.

Florida Administrative Code 59A-36.008 Medication Practices (3)(h) is very clear:

“All trained staff must adhere to the facility’s infection control policy and procedures when assisting with the self-administration of medication.”

This requirement applies every single time a staff member assists with medications—and especially between residents.

The Real Problem Surveyors See

One of the most common deficiencies cited under this rule is failure to sanitize hands between residents during medication pass.

It often looks like this:

• Staff sanitize before starting med pass

• Medications are passed to multiple residents

• Hands are not sanitized between residents

Surveyors view this as a direct infection control failure, regardless of how “quick” or “low risk” the interaction may seem.

Gloves Are Not the Solution

Many facilities try to fix this by requiring staff to wear gloves during med pass. In reality, this often creates a bigger compliance problem.

If gloves are worn:

• Gloves must be changed after each resident

• Hand hygiene is still required after glove removal

• Failure to change gloves between residents is also a deficiency

In practice, glove use often leads to false confidence and inconsistent compliance.

👉 Recommendation: Gloves should be used only when clinically indicated—not as a substitute for hand hygiene during routine med pass.

The Simple, Survey-Friendly Fix

The most effective and realistic solution is also the simplest:

A large, visible bottle of hand sanitizer on the medication cart.

This:

• Removes excuses

• Makes compliance easy

• Reinforces infection control expectations

• Is immediately observable to surveyors

If the sanitizer is right there, there is no reason it shouldn’t be used between every resident.

“Washy Washy” — A Culture Cue That Works

If you’ve ever been on a cruise ship, you’ve seen it.

Before entering the buffet, there’s always a handwashing station—and a staff member cheerfully reminding guests: “Washy washy!”

I like to use this same approach in assisted living facilities.

When:

• Observing med pass

• Walking the halls

• Making routine rounds

A lighthearted but consistent reminder like “washy washy” reinforces expectations without confrontation. Over time, it becomes part of the culture—and staff start reminding each other.

Bottom Line

Failure to sanitize hands between residents during medication assistance is one of the most avoidable deficiencies under 59A-36.008.

Facilities that:

• Reinforce hand hygiene expectations

• Avoid overreliance on gloves

• Keep sanitizer easily accessible

• Actively observe and coach staff

dramatically reduce their risk of citation.