Safe Medication Disposal: A Guide for Home-Based Care Providers

Written by Dr. Jennifer Kennedy

As a home-based care provider, you play a critical role in ensuring the well-being of your patients, including helping them manage their medications safely. Oversight of proper medication disposal is an essential part of this responsibility.

Unused Medications In the Home

The utilization of prescription and over the counter (OTC) medications has risen significantly in recent decades, attributable to increased accessibility, greater public awareness of their potential to address health concerns, and individuals seeing multiple physicians. Additionally, demographic shifts such as an aging and longer-living population contribute to this trend. 

The issuesⁱ

• Unused medications at home raise concerns about accidental overdoses, drug misuse or sales, and environmental risks. 
• According to multiple studies of individuals prescribed opioids for chronic and acute pain, less than a third reported disposal of unused opioid medications.ⁱⁱ
• As many as one third of hospices have reported at least one case of confirmed drug diversion, with many more cases suspected.ⁱⁱⁱ
• Many consumers improperly dispose of medicines in the trash, toilet, or sink, leading to environmental contamination and harm to ecosystems and living beings.

Medication Disposal in Home Health

Managing drug disposal in home care is complicated by federal rules aimed at preventing misuse and state laws that prioritize public health and environmental protection. Although federal regulations usually exempt household pharmaceutical waste from hazardous waste laws, they do not allow home health workers to manage controlled substances. This means patients or their families are typically responsible for disposing of these drugs unless there are specific authorized or state-approved programs available.^iv

Best practices for home health medication disposal include^v:

• Drug Take-Back Programs: The preferred method is using DEA-authorized collectors, such as community drug take-back sites, pharmacy kiosks, or mail-back programs.
• In-Home Disposal (if take-back is not possible):
  • Disable the medication: Remove drugs from their original containers and mix them with an undesirable substance like kitty litter, dirt, or used coffee grounds.
  • Seal and discard: Place the mixture in a sealable bag, empty can, or other container to prevent leakage, then place it in the household trash.
  • Remove personal information: Scratch out or destroy all personal information on the empty medicine bottle before disposing of it.
• Medication Deactivation Products: Use, or instruct families to use, commercial, at-home disposal products that contain activated charcoal to break down the drugs.
• Flushing: Only flush medication if it is on the FDA’s “Flush List” (e.g., certain strong opioids) and if a take-back option is not immediately available.

Medication Disposal in Hospice

The SUPPORT for Patients and Communities Act (Pub. L. 115-271, the “Act”) was signed into law on October 24, 2018. The law permits (but does not require) a qualified hospice program’s licensed physicians, physician assistants, and nurses who meet certain requirements to dispose of controlled substances which were lawfully dispensed to the person receiving hospice care in the following situations^vi: 

• the disposal occurs after the patient dies in hospice care;
• the controlled substance is expired; or 
•  (I) the employee is— 
  • the physician of the person receiving hospice care; and
  • registered under section 303(f) [of the Controlled Substances Act];
    and
• (II) the hospice patient does not need the controlled substance due to a change in their care plan.

There are certain requirements and restrictions under the Act applicable to such disposal, including:

1. Dispose onsite following all relevant federal, state, tribal, and local laws.
2. Authorized employees must act within their employment scope as defined by state law.
3. The hospice must train authorized employees on the disposal of controlled substances. 
4. The hospice must have written policies and procedures for the disposal of the controlled substances.
   1. The Act specifically requires such policies only for assisting in the disposal of controlled substances after a patient’s death, but it is recommended hospice providers consider implementing policies that speak to the other disposal situations and requirements of the Act as well.
5. When controlled substances are first ordered, the hospice must provide copies of their drug disposal policy to the patient/family/caregiver which discusses disposal of controlled substances after a patient’s death. Additionally, hospice providers are required to communicate their policies to patients and families in clear, understandable terms, and to document in the patient’s clinical record that the written policies and procedures have been both provided and discussed.
6. If the family/caregiver opts for hospice staff assistance with drug disposal after the patient’s death, the hospice provider must document in the clinical record the type of controlled substance, dosage, route of administration, and quantity so disposed, and the time, date, and method of disposal. While not included in the Act, it is recommended to obtain a signature from the family member or caregiver who did the disposal.

If the family/caregiver opts for no assistance with controlled substance disposal, the hospice provider should document all drugs being left in the home in the clinical record including the following:

• The type of controlled substance, 
• dosage, route of administration, and 
• quantity.

While not included in the Act, it is recommended to obtain a signature from the family member or caregiver who refused disposal.^vii

It is critical that home health and hospice providers check their state regulations for laws that govern controlled substance and other medication disposal.

Educating Patients About Medication Disposal 

Home-based care providers should educate patients/families/caregivers about safe medication disposal. Education should begin with the encouragement of take-back programs as the preferred method. Alternatively, the “mix-place-throw” protocol involves combining medications with substances such as dirt, cat litter, or coffee grounds, sealing them in a bag, and discarding them in household trash after obliterating personal information. Providers who work in home settings should stress the importance of removing prescription labels to prevent identity theft and advocate for the proper handling of sharps to ensure safety.

Most medicines, including pills, liquids, patches, and creams, should not be flushed in the toilet. Only a very specific FDA Flush List of dangerous, mostly opioid, medications should be flushed if a take-back program is unavailable. All other medications should be disposed of in the trash using a secure mix (e.g., dirt, cat litter, coffee grounds).^viii

The Core Issue

Unused or expired medications in the home create safety, misuse, and environmental risks. Home‑based care providers play a crucial role in reducing these risks through education and guidance.

Key Takeaways

• Safe medication disposal is a core component of patient safety.
• Regulations differ between federal and state; know both and follow the more stringent regulation.
• Growing medication use increases the importance of disposal practices.
• Take‑Back programs are the gold standard for drug disposal
• In‑home disposal is a secondary but necessary option particularly for hospice
• Only a small subset of medications should ever be flushed
• Hospice care requires special sensitivity and legal precision
• Education is one of the provider’s most powerful tools

Resources:

FDA’s Flush List for Certain Medicines

What To Do with Unwanted Household Medicines

Drug Disposal: Drug Take-Back Options | FDA

Questions?

Contact CHAP