By Amir Amini
September 17, 2015

Amir's Quarterly "FYI" Email

Hello everyone,

It’s time for my quarterly “fyi” email.    Some things have gone on during surveys and with letters from CDPH that I think you should all know about.   Let’s start with survey stuff.  

Follow-up to the Recommendations

In multiple counties, surveyors are asking for copies of our audits to look for troubling trends at the facility.   In doing so, they’ve been putting a lot more emphasis on follow-up rates.  It used to be that facilities with >90% follow-up were doing great.   Now, I’ve been getting reports of surveyors questioning why even ONE of the recommendations haven’t been followed-up.  So I would highly recommend emphasizing 100% follow-up to the recommendations at facilities.  As far as the regulations are concerned, we will typically be asked “how do you notify the facility when a recommendation isn’t followed-up.”

Sliding Scales and Hold Parameters

Not too long ago, a facility failed survey because multiple med errors with respect to sliding scale and bp hold parameters.   The nurses were not giving the correct insulin doses that corresponded with a bs result on the sliding scale.   Also, they weren’t following BP parameters.  Holding when they should have been giving the med, giving the med when they should have been holding it.   We all see these errors quite frequently.    But be aware that every one of those is considered a medication error.  So if they find more than one or two, then they can get you on Scope and fail the survey.   The BP parameters are even more dangerous.   If a BP medication was given when it should have been held and the patient had a fall recently, then you know what the survey result will be….G or IJ for sure

Change of Condition IMRRs

IMRR policy where the facility is to send in an IMRR form and MARs for new admit, short-stay patients and/or change of conditions.   Please reinforce this during your next QA meeting.   Why is this important?   Type in the following terms in any search engine and read the article:

Pharmacy Law Liability of a Nursing Home Pharmacist Not Told of Drug Change

Without being notified of a change in condition of a patient, the pharmacy has no way of knowing if a patient is currently experiencing a medication related adverse event or is at a high risk for experiencing one.

 Medication-Related Adverse Events

CMS is thinking of implementing another survey tool.  This one is about medication-related adverse events.   According to CMS, there about 5-6 adverse events they consider to be “preventable” in the SNF setting.   For each of these events, they’ve implemented a tool for surveyors, consultants, and facilities to use in order to determine if all the appropriate steps were taken.   If they find gaps in any of the processes, then they can call it a “preventable” event. See the Survey and Cert letter from July 2015 detailing the content of the proposed form.  I plan on having a conference call with a couple surveyor supervisors to discuss which parts are consultant responsibilities and which parts are up to the facilities to follow.  Will keep you posted.


I talk about this with almost every “FYI” email.  But be aware that surveyors are scrutinizing antipsychotic use even more.   Just yesterday I got a call from a surveyor doing an MDS survey asking about psych GDRs.  Some surveyors are satisfied with our GDR notes with the MD signing to “continue” or “change dose”.   Other surveyors want even more clinical documentation justifying the continued use of a psych medication.   Guidelines state that we need to alert the facility/MD when a specific patient is due for a GDR with our notes.  But the physician should make sure there is sufficient documentation to warrant the continued use of the drug.  Simply signing our notes may not be sufficient. 

Author Description

Amir Amini

Amir is a Pharmacist Consultant at SCRx Pharmacy. He has years of experience working with the major SNF providers in Southern Ca.

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