By Carl Bryant
September 20, 2015

Medicare and Medicaid Programs; Reform of Requirements for Long-Term Care Facilities

Regarding the proposed rules contained in the federal registrar Volume 80, No. 136 for Thursday July 16th, 2015 (~500 pages) - There are numerous changes for every department in the skilled nursing facilities including pharmacy. The changes are in addition to the regulations already in place. Time is of the essence when CMS releases proposed regulations.  These changes are currently in a comment period - postponed till October 2015 - and will likely be implimented by end of year 2015

These are the primary changes identified for pharmacy.

  1. CMS failed to identify or acknowledge any funding associated for the pharmacy changes.

  2. Additional pharmacist’s chart reviews requirements.

  3. The pharmacist will need to review the chart: every 6 months, upon admission, returns from the hospital.

  4. DRR to include prescribed or taking “psychotropic drugs” antibiotics, drugs identified by the QAA.

  5. Psychotropic drug definition has been expanded.

  6. Report irregularities to Medical Director in addition to the DON and physician.

  7. Acted upon and documentation of DRR expanded.

  8. These items have been moved to pharmacy services:

    1. Unnecessary Drugs

    2. Duplicate therapy

    3. Excessive duration

    4. Adequate monitoring

    5. Adequate indications for use

    6. In the presence of adverse consequences

    7. Psychotropic drug usage

      1. Treat a specific condition

      2. PRN cannot exceed 48 hours

    8. Medication errors

  9. Policies and procedures to include ways to monitor for QAPI.

  10. Reconciliation of medications both prescribed and over the counter for resident discharges.

  11. Additional requirements for antibiotic use for the infection control program.

  12. QAPI requirements for every department.

  13. Pain management

This is just a summary of the regulations, some of them are very specific. Should these regulations become active we at SCRx are working to be up and running to accomadate these changes at the time they become effective. 

Author Description

Carl Bryant

Carl is a Compliance Consultant at SCRx pharmacy that has worked and consulted with numerous skilled nursing facilities to maintain regulatory compliance for more than 15 years. Carl is also a previous surveyor and trainer for the state surveyors.

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