Consultant Pharmacist Service Contracts: Before You Renew

Consultant pharmacist services are a CMS requirement.  Often service contracts specify a 12-month duration with an option to automatically renew annually. The auto-renewal option is convenient for the consultant and the facilities. However, as a consultant pharmacist, I would strongly encourage facility executives and administrators to annually review the consultant pharmacist performance before renewing a service contract.

"We did not know"

When I visit a facility for the first time I always ask for the pharmacy binder and review the previous consultant's summary and recommendations. Unfortunately, I often find an incomplete binder, vague reports or few recommendations. When I provide the corporate summary and recommendations for the facility, I often hear, "We did not know!"

Before renewing a service contract, ask the following questions.

1.  Does the consultant pharmacist consistently review medication storage and administration?

The consultant pharmacist should be reviewing medication storage in the medication rooms and carts routinely. The consultant pharmacist should also perform medication pass observations to assess the medication pass error rates. 

2. Does the consultant pharmacist perform a chart review for each resident every month?

According to CMS State Operations Manual Appendix PP, "The pharmacist performing the monthly MRR must also review the resident’s medical record to appropriately monitor the medication regimen and ensure that the medications each resident receives are clinically indicated." With this in mind, generally speaking, most facility will have more that 15 recommendations per month.  In addition, CMS has also indicated that it should take a consultant pharmacist approximately 20 minutes per MRR. Meaning, a facility with 100 resident should require about 33 hours of charting.

3. Are your reports submitted in a secured manner and in a timely fashion?

Effective November 28, 2017, each facility should have a policy and procedure that specifies the manner and timeframe in which MRR reports should be submitted. MRR reports include HIPAA secured information. These reports should be sent in a HIPAA secure manner, such as HIPAA secure faxing or encrypted emails. The timeframe for submitting these reports will help ensure timely responses to recommendations. The new interpretive guidelines also specifies that the consultant pharmacist should send the MRR recommendations to the medical director and attending physician directly. The facility must ensure that the medical director and attending physician contact information is readily available and current.

4. Are dangerous drugs and controlled substances being properly destroyed? 

Dangerous drugs that are to be destroyed should be documented appropriately and stored in a secured bin for destruction. Controlled substances that are to be destroyed should be documented appropriately and secured separately from dangerous drugs in a doubled locked, permanently affixed storage compartment. The inventory sheets for destruction should include all legally required information. It is a good practice to destroy medications each month to avoid the risk of diversion and non-compliance. 

5. Does your consultant provide training and development resources, and participate with QA meetings?

According to the CMS State Operations Manual Appendix PP the consultant pharmacist should identify the facility educational/informational needs about medications and provide credible information resources to the facility. The consultant pharmacist should also interact with the quality assessment and assurance committee to develop procedures and evaluate pharmaceutical services.  

6. Did your facility have pharmacy service deficiencies on your last survey?

The consultant pharmacy should assist the facility in identifying and reducing the risk for pharmacy service deficiencies before the facility receives a tag. Please note, once a deficiency is identified, correcting the deficiency is a process and can take some time.

Facilities can evaluate their current consultant pharmacist services at any point during the service contract. If you determine that you are no longer satisfied with your consultant pharmacist services, consult your attorney for legal advice, most contracts have a 30 day written notice of termination option.