Medication Pass and Pharmacy Services Revised Guidance 

State Operations Manual, Appendix P - Survey Protocol for Long Term Care Facilities - Part I, Revised Sept 15, 2006, CMS 

Sub-Task 5E – Collapses current regulatory language into three tags

(F425, F428, and F431) in Appendix PP, State Operations Manual, as well as medication related revisions in Appendix P Task 5 and Sub-Tasks 5A, 5C, and 5E

This revised guidance will be effective December 18, 2006. At that time, a final copy of the new guidance will be available at http://www.cms.hhs.gov/Transmittals/ and ultimately incorporated into Appendix PP of the State Operations Manual. System changes will be effective the same date. 

1. Medication Pass

2. Medication Storage

3. Controlled Medications

4. Pharmaceutical Services

5. Unnecessary Drugs / Medication Management

Brief Overview:

In the first four areas, there are not recommendations for radical changes in facility policy and procedure. It does appear that surveyors will look longer and deeper at facility practices, and it would be wise for facilities to develop Quality Assurance audits and checklists to monitor compliance. 

Regarding Unnecessary Drugs / Medication Management, the revised guidance states:

Under these regulations, medication management includes consideration of:

1. Indications for use of medication (including initiation or continued use of antipsychotic medication);

2. Monitoring for efficacy and adverse consequences;

3. Dose (including duplicate therapy);

4. Duration;

5. Tapering of a medication dose/gradual dose reduction for antipsychotic medications; and

6. Prevention, identification, and response to adverse consequences. 

LTCS recommends making a full medication review part of the resident’s care plan meeting. Each of the resident’s medications should be carefully analyzed:

Is there a supporting and appropriate diagnosis?

Are signs and symptoms still present that justify usage?

Has the medication been evaluated to make sure usage does not conflict with the resident’s conditions and/or other medications?

When was usage and dose last evaluated by the physician?

Is the dose appropriate?

Are there duplicate medications?

Is there evidence of adverse consequences? 

The revised guidance contains a lengthy table of common medications with recommended dose, indications, and possible adverse consequences.

Care plans should include each of the resident’s medications, with interventions for evaluating dose and duration and monitoring for potential side effects. These can be incorporated into existing care plans as it is appropriate.