The Insulin Storage Mistake Getting ALFs Cited — How to Stay Compliant With AHCA Rules

The Insulin Storage Mistake That Keeps Getting ALFs Cited — And How to Avoid It
🧊 The Insulin Storage Mistake That Keeps Getting ALFs Cited — And How to Avoid It

If there’s one medication storage issue AHCA cites over and over again, it’s this:

👉 Refrigerated medications — especially insulin — not being locked.

You can have perfect MARs, perfect counts, perfect documentation…

but if your insulin is sitting in an unlocked fridge, AHCA won’t overlook it.

And this is one of the easiest deficiencies to prevent.

What the Regulation Actually Says

Under 59A-36.008(6)(c), centrally stored medications must be:

  1. Kept in a locked cabinet, cart, or other locked storage at all times, and 
  2. Medications requiring refrigeration must still be secured 

That means refrigerated medications must be kept:

  • In a locked container inside the refrigerator, OR 
  • In a locked refrigerator, OR 
  • In a locked room where the refrigerator is located 

Any one of those three options is acceptable — as long as access is restricted.

If it’s not locked, it’s a deficiency.

Every time.

Why Insulin Is the #1 Problem

Most ALFs get cited specifically for insulin left in a refrigerator in:

  • The kitchen 
  • A staff breakroom 
  • A dietary fridge 
  • A shared medication refrigerator without a lockbox 

Even though insulin needs refrigeration, the law still considers it a centrally stored medication — meaning it must be secured.

If staff or residents have free access to that fridge, you’re out of compliance.

This is why insulin is one of the most common citations under this rule.

Home Health Staff Are a Major Source of Citations

Another issue that gets facilities cited all the time is home health staff coming in to administer insulin.

Here’s the problem:

❌ They take the insulin out of the lockbox

❌ Give the medication

❌ And then put it back unlocked, or don’t secure it at all

Even though they made the mistake…

👉 YOU are still responsible for that insulin being secured.

Facilities often let home health nurses, LPNs, or aides:

  • Go into the refrigerator themselves 
  • Open the lockbox 
  • Remove the insulin 
  • Put it back on their own 

That’s where the trouble starts.

You cannot assume they will lock it properly.

You cannot assume they understand ALF storage regulations.

And you cannot assume they will remember each time.

Home health agencies do not get cited — the ALF does.

My Strong Recommendation

To avoid this extremely common deficiency:

✔️ Have your staff control access to the insulin lockbox

✔️ Your staff should remove the insulin and hand it to home health

✔️ After administration, your staff should lock it back up

✔️ Document the hand-off process (simple signature or staff initials works)

This closes the compliance gap and keeps your facility protected.

How AHCA Checks This During a Survey

Surveyors will:

  • Ask to see where refrigerated medications are stored 
  • Check whether the fridge or room is locked 
  • Look inside for insulin or other refrigerated meds 
  • Try to open the lockbox 
  • Ask who has access 
  • Observe if insulin is easily accessible 

If they can access insulin without a key or code?

They cite it immediately.

It’s one of the fastest citations AHCA writes.

Acceptable Ways to Be in Compliance

You only need one of the following:

✔️ 1. A Lockbox Inside the Fridge

This is the most common solution.

Purchase a medication lockbox or small lockable container and place insulin inside it.

✔️ 2. A Locked Refrigerator

If the entire fridge stays locked at all times and only medication staff have access, you’re compliant.

✔️ 3. A Locked Medication Room

If the refrigerator sits inside a medication room that is locked at all times, that is also acceptable.

Any of these options works — as long as the medication is not accessible to unauthorized individuals.

Common Mistakes Facilities Make

These are the problems I see repeatedly:

❌ Insulin in a fridge with no lockbox

❌ Insulin in a dietary or kitchen refrigerator

❌ A “med room fridge” that isn’t actually locked

❌ Storing insulin in a plastic container or drawer (not locked)

❌ Allowing home health to access the fridge without a staff member

❌ Assuming “only staff use this fridge” counts as being secured

None of these meet the regulation.

If AHCA can open it — it’s noncompliance.

The Fastest Fix You Can Make Today

Buy a refrigerator lockbox for each insulin-dependent resident or for your med fridge.

These are inexpensive, easy to install, and eliminate one of the most preventable citations in assisted living.

I strongly recommend you:

✔️ Audit your refrigerators today

✔️ Confirm insulin is secured properly

✔️ Ensure home health is not accessing insulin unsupervised

✔️ Document your correction if needed

This is a quick win that protects your license and your residents.

Final Thought

Medication storage is one of the most cited areas in assisted living, and insulin is almost always the culprit.

A simple lockbox — paired with a policy that your staff control access — can protect you from:

  • A deficiency 
  • A complaint 
  • An investigation 
  • A repeat citation 

It takes 10 minutes to fix and eliminates one of the easiest survey risks in the building.