What phase 2 of the Final Rule will bring for post-acute care pharmacy.

Changes Are Coming: The Implications of CMS Final Rule Phase 2 for Post-acute Care Pharmacy

Last year, the Centers for Medicare & Medicaid Services introduced multiple new regulations that affect long-term care pharmacy. The Final Rule for long-term care facilities participating in Medicare and Medicaid programs was published by CMS on Oct. 4, 2016.  

The three phases of these regulations have implementation dates of Nov. 28 in 2016, 2017, and 2019. Because these are the most significant and comprehensive regulation changes in recent history, there are multiple sections that have implications for medication use.

One of the most important medication-related changes concerns psychotropic medications. These changes affect both how psychotropic medications are defined and how they are prescribed, both of which impact post-acute care pharmacy.

Defining Psychotropic Medications for Post-acute Care Pharmacy

According to the final rule, a psychotropic medication will be defined as any medication that affects brain activities associated with mental processes and behavior. This includes—but is not limited to—medications in the following categories: antianxiety, antidepressant, antipsychotic, and sedative-hypnotic.

Previously, the focus was primarily centered around antipsychotic medications, so added attention will need to be provided to these additional classes of medications.  Several of the required provisions are intended to reduce or eliminate the need for psychotropic medications, if not clinically contraindicated, to safeguard residents’ health.

What the Changes Mean for Post-acute Care Pharmacy

As part of phase 2, there are several changes related to the prescribing of psychotropic medications. According to the final rule, when prescribing psychotropic medications based on a comprehensive assessment of a resident, the facility must ensure that:

  1. Residents who have not previously used psychotropic medications are not to be given these medications unless the medications are necessary to treat a specific condition as diagnosed and documented in the clinical record.
  2. Residents who use psychotropic medications should receive gradual dose reductions and behavioral interventions, unless clinically contraindicated, in an effort to discontinue these medications.
  3. Residents should not receive psychotropic medications pursuant to a PRN (“as needed”) order unless the medications are necessary to treat a diagnosed specific condition that is documented in the clinical record.
  4. PRN orders for psychotropic medications are limited to 14 days and cannot be renewed without proper documentation. If the attending physician or prescribing practitioner believes that it is appropriate for the PRN order to be extended beyond 14 days, they should document their rationale in the resident’s medical record and indicate the duration for the PRN order.

Resident-centered care with the goal of maintaining the highest mental, physical, and psychosocial well-being is a focus of these requirements.

Other Changes of Significance for Post-acute Care Pharmacy

One provision that will be implemented in phase 2 is that the resident’s medical chart must be reviewed every month as part of the monthly medication regimen review.

The facility must develop and maintain policies and procedures for the monthly medication regimen review that include timeframes for the different steps in the process as well as steps that the pharmacist must take when he or she identifies an irregularity that requires urgent action to protect the resident.  

These changes have already been previously implemented by your Grane Rx LTC pharmacy services team.

The final rule implements regulatory changes that may lead to a reduction in the unnecessary use of psychotropic medications (such as antipsychotic medications) and improvements in the quality of behavioral health care. Medications are often an integral part of interventions and plans of care, which require ongoing interdisciplinary collaboration. Medication stewardship needs to be a multidisciplinary effort that includes the ongoing participation of the post-acute care pharmacy team.

Access to information is critical for all team members. Overcoming obstacles to accessing and documenting medication care plans within electronic medical records across the continuum of care needs to be part of this ongoing work. Continuing advocacy and interprofessional engagement are needed to improve the delivery of care for the post-acute care setting and the residents who are served.

The Grane Rx team works diligently to analyze and review regulatory and guideline changes, then put that information into action. Could your SNF benefit from our services? Call (866) 824-MEDS (6337) to find out more.

mm

Jennifer Devinney is the Chief Clinical Officer for Grane Rx. In this role, she works with clinical pharmacists and nurses in conjunction with facility staff to develop and oversee clinical initiatives. Additionally, she is the clinical EHR integration specialist.


Categories: Clinical Care Advantage

Facebooktwittergoogle_plusredditpinterestlinkedinmail