Changes to the Interpretive Guidelines

Several changes to the CMS Interpretive Guidelines became effective November 28th, 2017.  Find out how these changes affect pharmacy services, and how to ensure that your facility is compliant. 

Drug Regimen Reviews

The consultant pharmacist must perform a Drug Regimen Review for each resident each month. The DRR must be sent to the attending physician, director of nursing, and the medical director. The facility should have a policy that addresses procedures for DRR notifications, responses, and timeframe.

Psychotropic Drugs

Psychotropic drugs have been defined as any drug that affects brain activities associated with mental processes and behavior. PRN psychotropic medication orders should be limited to 14 days. There is an exception if the prescriber provides and documents a clinical rational for the extension, indicates the extension is medically appropriate, and specifies the duration of the extension. PRN antipsychotic medication orders should be limited to 14 days.  These orders cannot be extended beyond 14 days. If continued therapy is needed, the resident must be seen by the prescriber and a new order must be written.

Infection Control Program 

Facilities must establish an infection prevent and control programs, which should include an antibiotic stewardship program with antibiotic use protocols and a system to monitor antibiotic use.  The CDC has developed implementation resources including "Core Elements for Antibiotic Stewardship in Nursing Homes".  See the link below.

Revised F-Tags

The CMS revised F-Tags became effective November 28, 2018. The links below are two CMS resources to outline the changes.