When Unlicensed Staff Work in the Infirmary

It's a common practice across the camp industry for us to have non-medical professionals taking on various roles in the infirmary. Camps often have a large health center support staff, which may include office managers, infirmary assistants, nursing assistants, health center interns, and various others with similar titles.

Unlicensed support staff can handle many day-to-day tasks, but their work has boundaries. The real issue is determining which duties they may perform without stepping into functions that the law reserves for licensed professionals. What exactly are those functions?

Camp regulations typically don't answer this question directly. The legal issue hinges on how state law defines and regulates the "practice of medicine" and the "practice of nursing." Because only licensed individuals may legally perform the activities classified as medical or nursing practice, the key question becomes which actions the state places in those categories.

For example, let's consider the administration of medication. In many states and under widely accepted interpretations of medical and nursing practice acts, administering medication is treated as a professional medical or nursing function. That means the task is restricted to licensed professionals unless a state has created a specific exception for camps.

Some states have laws that allow non-medical professionals to administer medications in various settings. For example, in some states, non-medical professionals who receive special training are allowed to administer medications in group homes and residential treatment facilities, but we have to make sure the carveout extends to camps.

For example, Pennsylvania has a law (55 Pa. Code § 6100.462) saying that medications may be administered by doctors, nurses, and any "person who has completed [certain] medication administration course requirements." At first glance, a well-meaning staff member may assume that this applies to camps: We can simply train our lay staff on medication distribution, and then they're allowed to hand out medicine to campers, right? Unfortunately not.

Those types of carveouts apply only to the specific settings named in the statute or regulation. While it isn't obvious from the webpage where the Pennsylvania language appears, that particular law applies only to "Services for Individuals with an Intellectual Disability or Autism." We would need to find a similar exception for camps (which, by the way, I have not been able to find in Pennsylvania).

The point is that, unless a state has enacted a camp-specific rule saying otherwise, the legal framework that most camps must consider is their state’s nursing or medical practice act and any official guidance interpreting those statutes. Many state health departments and boards of nursing take the position that unlicensed individuals may not administer medication to others and that licensed nurses may not delegate this duty to unlicensed staff. Where that interpretation applies, medication administration by camp staff is viewed as practicing nursing or medicine -- and is therefore limited to licensed professionals.

Of course, this is where self-administration comes in, assuming state law permits it. Many camps without licensed medical staff rely on self-administration policies that allow campers to take their own routine medications with appropriate supervision. When the policy is structured correctly, an unlicensed staff member may oversee a camper’s self-administration without crossing into the practice of medicine or nursing. This approach is widely used among camps.

Simply put, we need to make sure that out unlicensed staff are not performing tasks that state law classifies as medical practice. When lay staff cross that line, the camp risks regulatory violations and unnecessary liability. The safest and most traditional approach is to reserve true medical care for licensed professionals.