| Nursing Facility Survey & Regulations Quick Links | Updates | Background | December 2006 Changes to Pharmacy Sections of SOM | Products/Resources Quick Links
Updates September 29, 2008 Office of Inspector General (OIG) Releases Report: "Trends in Nursing Home Deficiencies and Complaints" This report describes the nature and extent of nursing home deficiencies and complaints in 2007 and identifies trends from 2005 to 2007. From 2005-2007, over 91 percent of nursing homes surveyed were cited for deficiencies. The most common deficiency categories cited were quality of care, resident assessment, and quality of life. "Pharmacy Services" was the 7th most frequently cited category, and it was the one category that experienced the greatest increase in deficiencies from 2005-2007, largely due to the new Interpretive Guidelines that went into effect in December 2006. In 2005, 23.8% of nursing homes were cited for deficient "Pharmacy Services," whereas in 2007, 28.8% of facilities were cited. The report also provides state-specific deficiency statistics. Click here to download the report. June 20, 2008 CMS Releases New Interpretive Guidelines for F-Tags 325 (Nutrition) and 371 (Sanitary Conditions) F-Tag 325 (Nutriton) mentions pharmacists and medications frequently throughout the new Interpretive Guidelines. Consultant pharmacists should be familiar with these new guidelines to help their facilities identify ways in which medications may impact nutrition. June 18, 2008 CMS Announces New Ranking System for Nursing Facilities Using 5-Start System. The ratings will be posted on the agency's Nursing Home Compare Web site by the end of 2008. A sample screen shot of the proposed star ratings is available. The Nursing Home Compare website can be found at http://www.medicare.gov/nhcompare. February 12, 2008 CMS Releases an Updated List of Nursing Facilities Who Performed Poorest on Surveys (also referred to as Special Focus Facilities) January 18, 2008 CMS Issues S&C Memo (S&C-08-10) Reminding Surveyors to Cite Deficiencies Based on Regulations, not Permissive Activities Mentioned in Interpretive Guidelines The memo reminds surveyors that all survey deficiencies cited must be based on a violation of statutory and/or regulatory requirements. The memo states: “Permissive duties (mentioned in the Interpretive Guidelines) are not requirements, and the lack of use of any particular tool does not, by itself, constitute sufficient grounds for the citation of a deficiency.” Changes to SOM Survey Guidance Within Past 4 Years
Background All nursing facilities are subject to inspection or survey by virtue of their:
The information contained in this section applies to both the skilled nursing facility (SNF) and the nursing facility (NF) categories of facilities. (See Glossary located in Appendix A of SOM for definitions of these categories.) Not only will these standards be reviewed during the facility’s annual survey, but they may also be reviewed during any inspection resulting from a complaint against the facility. Furthermore, any deficiency cited against the facility will result in regulatory and/or monetary penalties to the facility, will become a part of the public record about the facility, and may reflect poorly on the providers and facility. The SOM has multiple components and sections. Appendices P, PP, and R of the SOM are the three appendices related to the nursing home setting.
For example, SOM Appendix PP contains CFR Section 483.60 dealing with the standards for providing pharmacy services to a long-term care nursing facility. This section of the regulations is divided into three F-Tags: F-425, F-428, and F-431. The “F” preceding the term “Tag” indicates that the section pertains to long-term care facilities and can be found in Appendix PP. Each SOM Appendix has its own Tag designation (e.g., W-Tags for ICFs, G-Tags for Home Health Agencies, etc.). When a survey identifies a deficient practice and non-compliance with the regulations and guidelines, the surveyor must name the specific Tag under which the deficient practice falls. This is how the citation is officially classified and documented. It is important for the consultant pharmacist to understand all regulations and interpretive guidelines applied to these facilities, especially those that relate specifically to pharmacy. The major pharmacy-related F-Tags include:
Chapter 7 and Appendix P of the CMS State Operations Manual contains information about the step-by-step process used by surveyors when conducting a survey of a nursing facility. ASCP has put together a brief summary of the survey process, which answers questions such as: How surveys nursing facilities? How are surveyors trained? How often do surveys occur? What is this new “QIS” survey? How do I find information about my facilities’ survey performance/record? What are the components of a “plan of correction” in response to a deficiency? December 2006 Changes to Pharmacy Sections of SOM On December 18, 2006, CMS implemented revised versions of the pharmacy-related sections of SOM Appendices P and PP. The changes affected the:
Archived Webcast: “Gradual Dose Reduction/Tapering Myths Versus Reality – A Clinical Perspective” Even though the Centers for Medicare and Medicaid Services (CMS) regulations and guidelines require or suggest tapering of medications, the clinical implementation of such a tapering attempt can be complicated in the long-term care population. This session will attempt to address the practical application of the tapering guidelines for each of the medication classes mentioned in the CMS document (i.e., psychopharmacological, antipsychotic, sedative/hypnotic) while focusing on relevant current standards of practice and recent clinical trials that inform such practice. Archived Webcast: “Gradual Dose Reduction/Tapering Myths Versus Reality – A Regulatory Perspective” The Centers for Medicare & Medicaid Services (CMS) made significant changes to the survey guidelines of the State Operations Manual (SOM) related to gradual dose reductions and tapering. In addition, the final version of the guidelines released in December 2006 contained several notable alterations from the Advance Copy released in September. This program will outline these specific changes and clarify the correct final guidelines; define psychopharmacological medications and the rationale for tapering; describe criteria and necessary documentation for clinical contraindications; and discuss the impact of the new guidelines. Summary of Changes and Answers to Frequently Asked Questions The Consultant Pharmacist journal article: “Changes in the State Operations Manual: Implications for Consultant Pharmacy Practice” – December 2006 The Consultant Pharmacist journal article: “Implementing Changes to the State Operations Manual” - February 2007 The Consultant Pharmacist journal article: “Gradual Dose Reduction and Medication Tapering: A Clinical Perspective” – August 2007 Products/Resources Policies and Procedures: Pharmacy Services for Nursing Facilities Extensively updated in 2006 to address the changes to the pharmacy sections of the CMS State Operations Manual SOM Quick Reference Cards
Contains Appendix P and Appendix PP from the CMS State Operations Manual along with forms used by surveyors during their survey of nursing facilities Unnecessary Medications in the Elderly: A Guide to Improving Therapeutic Outcomes Focuses on effective care delivery processes for the management of medications The Consultant Pharmacist Handbook: A Guide for Consulting to Nursing Facilities Includes sections on:
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