At the end of September, CMS finally approved and released the roll-out schedule for the long- awaited Final Rule, which includes some regulations related to LTC pharmacy services. Phase 1 was effective on Nov. 28, 2016, and Phase 2 will be effective on Nov. 28, 2017. The Final Rule encompasses the first major revisions to the Nursing Home Requirements for Participation since 1987, and it touches on essentially every aspect of our scope of practice, including long term care pharmacy. Grane Rx has been reviewing the new regulation changes and is prepared to accommodate all of the required changes and to support Skilled Nursing Facilities during this transition. Read on for a look at the upcoming changes as they relate to post acute care pharmacy.
Long term Care Pharmacy & Monthly Medication Regimen ReviewsWith the new regulations, monthly medication regimen reviews must include a review of the resident’s medical chart. Grane Rx consultant pharmacists are already reviewing the resident’s medical chart and documenting the review accordingly in the chart on a monthly basis. There will not be changes to this practice. Any irregularities identified during the pharmacist’s monthly medication regimen review are to be reported in a separate report to the resident’s attending physician and the facility’s Medical Director and Director of Nursing. A new process and report was implemented by Grane Rx consultant pharmacists on Nov. 28, 2016, which will provide the aforementioned report to the identified parties. This change was in addition to our previous processes and methods of communication for recommendations and reports. As a reminder, all residents’ medication regimens must be free from unnecessary medications. An unnecessary medication is any medication that is being utilized in excessive dose (including duplicate therapies), for excessive duration, without adequate monitoring, without an adequate indication for use, or in the presence of adverse consequences—or any combination of these reasons. Additionally, when an irregularity has been identified by the consultant pharmacist, it is the responsibility of the resident’s attending physician to document that the irregularity has been reviewed and what action has been taken. Even if the attending physician disagrees with the recommendation and no action is taken, documentation must be provided for the rationale. This documentation should be part of the resident’s medical record. While changes to the Monthly Medication Regimen Review are not effective until Phase 2, Grane Rx is prepared to be in compliance at this time.
Long term Care Pharmacy & Psychotropic MedicationsThe definition of psychotropic medication has been changed and expanded to include any medication that affects brain activities associated with mental processes and behavior. This includes the following medication classes—antipsychotics, antidepressants, anxiolytics, and hypnotics. During medication regimen reviews and data reporting, Grane Rx consultant pharmacists are presently including and considering all of the above identified medication classes. Additionally, as regulated, consultant pharmacists monitor that psychotropic medications are being used to treat a specific condition that is diagnosed and documented in the resident’s clinical record. We also monitor and intervene to ensure residents who are receiving psychotropic medications receive gradual dose reductions and behavioral interventions, if appropriate, in an effort to discontinue these medications when possible. For Phase 2, specific focus and processes will be developed for PRN psychotropic medications. Beginning in Phase 2, the following conditions must be met for PRN psychotropic medications:
- Residents do not receive a PRN psychotropic medication unless that medication is necessary to treat a diagnosis-specific condition that is documented in their clinical records.
- PRN orders for psychotropic medications are limited to 14 days.
- If an attending MD or prescriber feels it is appropriate for the medication to be used longer than 14 days, rationale must be documented in the resident’s medical record and the duration of the PRN order must be indicated.
- PRN orders cannot be renewed unless the attending MD or prescriber evaluate the resident for appropriateness of the medication.