Failure to Maintain and Address Medication Regimen Reviews
Summary
The facility failed to ensure that monthly Medication Regimen Reviews (MRR) were properly reviewed, addressed by the physician, and maintained in the clinical records for four out of five residents reviewed. For multiple residents with complex medical histories, including dementia, diabetes, anxiety, depression, and other conditions, pharmacy reports documenting the MRR were missing for several months. The Director of Nursing (DON) was unable to locate these reports in the electronic medical record and acknowledged that she did not keep them as required. The DON also confirmed that there was no way to determine what recommendations the pharmacist had made, whether the medical director or nurse practitioner had agreed or disagreed with those recommendations, or if any rationale for decisions was documented. Interviews with facility leadership, including the DON and Nursing Home Administrator (NHA), revealed that there was no designated staff member ensuring that pharmacy consults were being addressed. The NHA admitted that the system for handling pharmacy consults was broken and deficient. Review of the facility's own policy confirmed that written communications from the pharmacist should become a permanent part of the resident's medical record, but this was not being followed. As a result, the facility was unable to demonstrate compliance with federal requirements for drug regimen review and documentation.
Plan Of Correction
For Resident #67, the consultant pharmacist completed a drug regime review and submitted it to the DON and attending physician. The DON assured that the practitioner addressed any recommendations in the DRR. For Resident #36, the consultant pharmacist completed a drug regime review and submitted it to the DON and attending physician. The DON assured that the practitioner addressed any recommendations in the DRR. For Resident #65, the consultant pharmacist completed a drug regime review and submitted it to the DON and attending physician. The DON assured that the practitioner addressed any recommendations in the DRR. For Resident #90, the consultant pharmacist completed a drug regime review and submitted it to the DON and attending physician. The DON assured that the practitioner addressed any recommendations in the DRR. The DON/designee audited the EMR for all residents and identified those residents who did not have a DRR in April 2025. The DON notified the pharmacist that these reviews needed to be completed. DON and ADON had a phone conference with the pharmacy consultant about our process and how to correct it. To ensure the pharmacy recommendations are being answered according to policy, the process needs to come back to an in-house process instead of reports being sent electronically to an outside source, Theoria. DON and ADON met with the DNP about changing the processing of pharmacy consultation reports by bringing the process back internally instead of sending them to Theoria to process. The DNP was in agreement. On 4/21/2025, it was confirmed that the pharmacist would be at the facility in person on 4/24/2025 to meet and discuss survey findings and finalize the plan to bring the process back to an in-house process. On 4/24/2025, the DON and ADON met with the consulting pharmacist to review the Medication Regimen Review policy and discussed the new process as follows: 1) After receiving monthly pharmacy recommendations, the ADON will print and separate them for delivery as follows: a. Nursing will be handed the recommendations to be given to the Administrative Medical Assistant to initiate processing. b. The physician will be handed the recommendations to be reviewed and responded to by the DNP and/or medical director. c. GDRs — a meeting will be scheduled for the Behavior Team to review and give their recommendations to the DNP/medical director for review and response. 2) Once all recommendations have been reviewed and have a response, all reports will be given to the charge nurse for processing. 3) A copy of the summary of MRRs will be given to charge nurses to indicate orders they process. 4) Recommendations will then go to HIM to be scanned into the residents' medical records. 5) The DON/ADON will review the completion of recommendations weekly. On 4/25/2025, the current Pharmacy Consultation Reports from the pharmacist with new and outstanding recommendations were received. On 4/28/2025, the DON and ADON reviewed all GDRs with the IDT. The ADON distributed all pharmacy recommendations to either the Administrative Medical Assistant for processing or the DNP for review. One-on-one direction was given to the DNP about the internal process by the ADON. To prevent pharmacy recommendations responses from being delayed and to ensure they are part of the residents' medical records, the following has been completed and/or initiated: DON, ADON, and pharmacy consultant reviewed and updated the Medication Regimen Review Policy and changed the response timeframes for the attending physician/DNP to: 1) 45 days (from 60 days), after which the DON will bring them back to the attending physician/DNP. 2) 50 days (from 65 days), after which the DON will notify the Medical Director and/or the Administrator. The ADON completed one-on-one education with all charge nurses on the change of the internal process. On 5/5/2025, the DON verified that the processing of April's pharmacy recommendations had been completed and all had been sent to HIM to be scanned into the residents' medical records. To ensure the changes implemented are followed, the DON/ADON or designee will review: 1) The monthly Pharmacy Consultation Summary Reports weekly for progress. 2) If by Day 30, a pharmacy recommendation has still not been addressed, the DON will bring it back to the attending physician/DNP for review per the ICMCFS Medication Review Policy. The DON/ADON or designee will audit completed recommendations for: 1) Completion of pharmacy recommendations by the attending physician/DNP with signature and rationale. 2) That completed recommendations have been added to the residents' medical records. Audits will be conducted as follows: 10 audits for 1 month, 6 audits for 1 month, and 4 audits for 1 month. The DON will present a compliance report based on the audit findings at monthly QAPI meetings for review by the team for 3 months, with recommendations by QAPI for further monitoring if consistent compliance has not been achieved. Ongoing monitoring thereafter will be continued by the DON/ADON to ensure compliance in accordance with the policy. The DON will be responsible for attaining and sustaining overall compliance with this plan of correction.
Penalty
Resources
Below are regulatory guidelines relevant to this citation:
A resident with dementia, depression, and hospice status had an open-ended PRN Haldol order for agitation and restlessness that was administered despite repeated CP recommendations to discontinue it. The record lacked the required face-to-face provider evaluation to justify continued use, and the DON stated she believed hospice status changed the 14-day PRN psychotropic review requirement.
A resident receiving quetiapine for Parkinson’s disease and behavioral disturbance had ordered AIMS monitoring that was not documented in the medical record, despite the consultant pharmacist’s recommendation for baseline and ongoing monitoring. The TAR showed sign-offs without assessment results, a blank entry, and later no sign-off at all, while staff stated AIMS was used to monitor side effects and should be documented in the chart.
Delayed Medication Regimen Review Follow-Up: The facility did not ensure timely follow-up on MRR recommendations for multiple residents. One resident with encephalopathy, MI, and respiratory failure had a pharmacy recommendation to review a psychotropic for possible dose reduction or discontinuation that was still not addressed when reviewed later. Two other residents with depression, anxiety, heart failure, and liver failure had missing or unlocated monthly MRR documentation, and the DON stated the records could not be found after a pharmacy change.
Pharmacy recommendations were not accurately carried out for two residents. One resident with multiple neuropsychiatric diagnoses had trazodone orders that did not match the actual 150 mg tablet being supplied, despite repeated pharmacist recommendations to update the order. Another resident with dementia and other chronic conditions had multiple eye drop orders, but the pharmacist’s instruction to allow 5 minutes between different drops was not added to the MAR/orders, and the DON confirmed the omission.
A pharmacist failed to complete an accurate medication regimen review because the hospital discharge summary and medication orders were not available in time. A resident with AFib and a history of falls was returned from the hospital with Eliquis documented to be discontinued, but the medication was entered and administered twice daily for 27 doses before the error was identified. The Pharmacy Services Director relied on transcribed orders and did not review the discharge summary, and the DON stated the hospital orders were not faxed or scanned promptly.
A resident with DM II, hyperlipidemia, and long-term insulin use had a pharmacist MDRR note recommending CMP, fasting lipid panel, and A1c monitoring, but the physician/prescriber response was left blank and the record showed no order or documentation that the recommendation was reviewed or acted on. Staff confirmed there was no evidence the labs were ordered, despite the facility policy requiring physician documentation of review and action on irregularities.
Unresolved PRN Antipsychotic Order Without Required Provider Evaluation
Penalty
Summary
The facility failed to ensure consultant pharmacist recommendations regarding a psychotropic medication irregularity were addressed for a resident with moderate cognitive deficit, dementia, congestive heart failure, diabetes, and depression who was under hospice care for end-of-life status due to heart failure. The resident’s record showed an active PRN order for haloperidol 1 mg every four hours for agitation and restlessness with an open-ended end date, and the PRN MAR documented administrations on 5/19/26 and 5/26/26. The resident’s care plan noted psychotropic medication use for depression and anxiety, and staff were to document three interventions before giving the PRN medication. Consultant pharmacist recommendation forms dated 3/9/26 and 4/3/26 recommended discontinuing the PRN Haldol because PRN antipsychotic orders were limited to 14 days unless the attending physician evaluated the resident for appropriateness of renewal. The physician signed one recommendation without further response or action, and no physician response was documented for the later recommendation. The medical record lacked a face-to-face assessment by the medical provider to justify continued use of the Haldol, and the facility’s DON stated she believed the regulation had changed for hospice patients. The facility policy also stated PRN psychotropic drug orders were limited to 14 days and could not be renewed unless the attending provider evaluated the resident.
Failure to Document and Complete Ordered AIMS Monitoring for Antipsychotic Use
Penalty
Summary
The facility failed to ensure a licensed pharmacist completed a monthly drug regimen review that included the medical chart and followed irregularity reporting procedures in its policies and procedures. For 1 of 5 residents reviewed for unnecessary medications, R6, the consultant pharmacist identified concerns related to quetiapine use and recommended adding AIMS monitoring at baseline and at least every 6 months unless already ordered, and reporting significant changes to the prescriber as soon as possible. A later pharmacist review noted that an AIMS order had been placed, but documentation showing the assessment was completed was not found in the record. R6’s record showed a quarterly MDS identifying moderately impaired cognition, rejection of care one to 3 days, and dependence on staff for dressing, bed mobility, and toileting. R6 was receiving quetiapine fumarate 25 mg by mouth daily for Parkinson’s disease and behavioral disturbance with agitation, along with 50 mg by mouth daily for the same conditions. Although a nursing order was entered to complete AIMS assessments, the TAR showed the order was signed off as completed on some dates without any assessment results documented, was blank on another date, and had no sign-off or documentation on later dates. During observation, R6 was seated in a wheelchair with a flat affect and mild finger tremor. Staff interviews stated AIMS was important for monitoring side effects and that completed assessments should be documented in the medical record.
Delayed Medication Regimen Review Follow-Up
Penalty
Summary
The facility failed to ensure that Medication Regimen Review (MRR) recommendations were implemented in a timely manner for 3 of 5 sampled residents reviewed for unnecessary medications. For Resident 1, the EHR showed diagnoses of encephalopathy, myocardial infarction, and respiratory failure, and the resident was able to make needs known. The pharmacy completed an MRR on 04/23/2026 and recommended reviewing the use of a psychotropic medication for possible discontinuation or dose decrease, but the recommendation had not been addressed by the provider when reviewed on 05/20/2026. Staff B, the DNS, stated the MRR should have been reviewed and addressed timely but was not. For Resident 150, the EHR showed a readmission with diagnoses including depression, anxiety, and heart failure, and the resident was able to make needs known. Consultation reports for March and April 2026 did not list Resident 150 as having new medication recommendations from the consulting pharmacist, and Staff B stated on 05/26/2026 that they had knowledge of the resident's MRRs for those months but were unable to locate any documentation. For Resident 122, the EHR showed diagnoses of liver failure and depression, and the resident was able to make needs known. The EHR showed an MRR completed on 05/20/2026, but no other monthly reviews were found in the EHR. Staff B stated on 05/20/2026 that the facility had recently changed pharmacies and was unable to locate the March and April 2026 MRRs, and that this did not meet expectations.
Pharmacy Recommendations Not Reflected in Medication Orders
Penalty
Summary
The facility failed to ensure pharmacy recommendations were completed accurately for two residents reviewed for pharmacy recommendations. For one resident with diagnoses including metabolic encephalopathy, depression, cognitive communication deficit, anxiety, and psychotic disorder with hallucinations, the chart showed repeated trazodone orders written as 1.5 tablets of 100 mg at bedtime for insomnia even after the pharmacist recommended changing the order to match what was actually being administered. The pharmacist first noted that the supplier was sending separate 50 mg and 100 mg tablets for a total dose of 150 mg, then later noted the supplier was sending a single 150 mg tablet, but the physician order was not updated to reflect the actual 150 mg tablet until later. The Director of Nursing confirmed the order should have been changed when the pharmacy recommendation was first made and again when it was repeated, but it was not accurately changed until the later order. For another resident with diagnoses including cerebral infarction, diabetes mellitus, hypertension, dementia, anxiety, major depressive disorder, and heart failure, the physician orders included multiple ophthalmic medications for both eyes. The pharmacist recommended adding instructions to allow 5 minutes between administration of different eye drops to all eye drop orders. Review of the physician orders showed that this instruction was not added to any of the applicable orders. The Director of Nursing confirmed the instructions had not been added and stated that nursing staff had been educated about allowing five minutes between eye drop administrations.
Pharmacist Did Not Identify Eliquis Discontinuation After Hospital Return
Penalty
Summary
The facility failed to ensure that a licensed pharmacist completed a monthly drug regimen review using the resident’s medical chart and the hospital discharge summary, as required by its policies and procedures. For one resident admitted with atrial fibrillation and a history of falls, the resident was sent to the hospital for weakness, recurrent falls, and a fall with a head strike that caused increased confusion. The hospital discharge summary indicated that Eliquis was to be discontinued because of repetitive falls and bleeding risk, and the summary also contained a handwritten notation crossing out Eliquis and initialed by the facility PA. When the resident returned to the facility, an order for Eliquis 5 mg twice daily was entered into the electronic record, and the medication was administered twice daily from 3/23/26 through 4/5/26 for a total of 27 documented doses. The Pharmacy Services Director stated he completed the initial pharmacy review based on the physician orders entered into the computer and did not review the hospital discharge summary because it was frequently not available at the time of the initial review. The DON stated the hospital medication orders were not faxed to the pharmacy and were not scanned into the resident’s electronic record for several days, which prevented the pharmacist from having the orders in time to complete an accurate medication review. The PA stated she had documented that Eliquis was to be discontinued, but later discovered the resident had erroneously received the medication and that the pharmacist had not identified the error on the initial review.
Pharmacist MDRR Recommendation Not Addressed
Penalty
Summary
The facility failed to ensure that irregularities identified in the Monthly Drug Regimen Review were acted upon for one sampled resident. Resident 5 was re-admitted with diagnoses including Type 2 Diabetes Mellitus, hyperlipidemia, and long-term insulin use. The resident’s MDS dated 3/25/2026 indicated severely impaired cognition and dependence for toilet use, personal hygiene, and showers/baths. A note from the facility pharmacist, printed 3/12/2026, asked the attending physician/prescriber to consider ordering a CMP, fasting lipid panel, and A1c based on Resident 5’s medications. The physician/prescriber response section was left blank, and there was no documentation in the record showing that the physician ordered the labs or otherwise documented agreement or disagreement with the pharmacist’s recommendation. During record review, the IP stated there was no physician order or documentation showing the labs were ordered, and the RN and DON stated the pharmacist’s recommendations were important for monitoring medications. The facility policy stated that the attending physician documents in the medical record that the irregularity has been reviewed and what action, if any, was taken.
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