Colorado Medication Administration Rules: QMAP vs. CNA-MED in Assisted Living

When it comes to medication administration in Colorado assisted living, understanding the differences between QMAPs and CNA-MEDs is critical. Both roles are authorized to administer medications, but they differ significantly in training, scope, and supervision. This guide breaks down everything you need to know to stay compliant, safe, and informed.

What is a QMAP in Colorado?

A Qualified Medication Administration Person (QMAP) is an unlicensed individual trained to safely administer medications in assisted living and other community-based care settings.

Key Facts:

• Must be 18+ and complete a state-approved training course
  
• Training includes classroom and hands-on med administration basics
  
• Must pass a written and practical competency exam
  
• Listed on the Colorado QMAP registry
  
• No formal renewal required, but pre-2017 QMAPs must retrain by Jan 1, 2025 (see Senate Bill 24-167)
  

Training requirements and scope of duties are outlined in 6 CCR 1011-1, Chapter 24

What QMAPs Can Do:

• Administer medications by oral, topical, inhaled, eye/ear, rectal, and vaginal routes
  
• Document doses in a MAR (Medication Administration Record)
  
• Observe and report side effects or changes
  
• Assist with properly labeled pill organizers
  

What QMAPs Cannot Do:

• Injections are not permitted (except emergency epinephrine in limited cases)
• Tube medications (G-tube, J-tube) and insulin are not allowed
• Assessment and PRN decision-making must be deferred to a nurse or physician
• QMAPs may not titrate oxygen, conceal medications, or pre-pour for later use
  

PRN Rules for QMAPs:

QMAPs may administer PRN meds only if:

1. The resident understands the purpose
   
2. The resident voluntarily requests it
   
3. A prescriber has documented approval
   (6 CCR 1011-1, Chapter 7, Section 14.9)
   

Otherwise, the QMAP must contact a nurse or physician.

What is a CNA-MED in Colorado?

A Certified Nurse Aide with Medication Aide Authority (CNA-MED) is a CNA who has completed additional state-approved training and passed a certification exam to administer medications under nurse supervision.

Key Facts:

• Must be a licensed CNA with 1,000+ hours of recent experience
  
• Complete a 5-credit Medication Aide Training Program
  
• Pass the Medication Aide Certification Exam (MACE)
  
• Apply for Medication Aide Authority through the Colorado Board of Nursing
  
• Renewal required every 2 years with 40+ hours of med aide work
  

CNA-MED rules are outlined in 3 CCR 716-1 – Rule 1.18

What CNA-MEDs Can Do:

• All QMAP tasks, plus:
  
  • G-tube and J-tube medication administration
    
  • Subcutaneous insulin injections (with RN dose verification)
    
  • Blood glucose testing
    
  • Vital signs before medication
    
  • Apply prescription creams and simple dressings
    

PRN Rules for CNA-MEDs:

CNA-MEDs may give PRNs only after contacting the supervising RN each time. They must document:

• Resident symptoms
  
• Nurse authorization
  
• Time given
  
• Outcome
  

Supervision Requirements:

• CNA-MEDs must be supervised by an RN (on-site or on-call)
  
• ALRs using CNA-MEDs must have systems in place to meet this requirement
  

QMAP vs. CNA-MED: Side-by-Side Comparison

Facility Responsibilities Under Colorado Law

Colorado assisted living residences (ALRs) must:

• Ensure at least one QMAP or CNA-MED is on-site when medications are needed
  
• Verify credentials through official state registries
  
• Designate a QMAP supervisor (required under 2025 rule update)
  
• Maintain policies for med storage, disposal, documentation, and controlled substances
  
• Ensure compliance with:
  
  • 6 CCR 1011-1, Chapter 24
    
  • 3 CCR 716-1
    
• Report and correct medication errors

How Synkwise Helps

Synkwise supports Colorado assisted living communities by:

• Digitizing MARs for accurate, time-stamped documentation
  
• Alerting staff about expired orders or missed doses
  
• Tracking PRN justification and documentation
  
• Verifying staff roles and qualifications
  
• Simplifying audits with built-in compliance tools

Need help staying compliant with Colorado’s med admin rules? ? Book A Demo today.

Sources

1. Colorado Secretary of State:
   The rule on medication administration: “6 CCR 1011-1, Chapter 24 – Medication Administration.”
   https://www.sos.state.co.us/CCR/GenerateRulePdf.do?ruleVersionId=10670&fileName=6%20CCR%201011-1%20Chap%2024
   The assisted living licensing rule: “6 CCR 1011-1, Chapter 7 – Assisted Living Residences.”
   https://www.sos.state.co.us/CCR/GenerateRulePdf.do?ruleVersionId=10416&fileName=6%20CCR%201011-1%20Chap%2007
   The nursing aide medication rules: “3 CCR 716-1 – Board of Nursing Rules for CNA-MEDs.”
   https://www.sos.state.co.us/CCR/GenerateRulePdf.do?ruleVersionId=10593&fileName=3%20CCR%20716-1
2. Colorado General Assembly: “Senate Bill 24-167.”
   https://leg.colorado.gov/bills/sb24-167