Failure to Limit PRN Psychotropic Medication Orders to 14 Days Without Physician Rationale
Penalty
Summary
Surveyors identified that the facility failed to comply with federal requirements regarding the use of PRN (as needed) psychotropic medications for two residents. Specifically, the facility did not limit the duration of PRN psychotropic medication orders to 14 days, nor did it ensure that the prescribing physician documented a clinical rationale for extending these orders beyond the 14-day limit, as required by regulation. For one resident with Alzheimer's disease and major depressive disorder, a PRN order for lorazepam was in place for a period exceeding 14 days. The resident was severely cognitively impaired and had no documented behaviors during the assessment period. The medication order for lorazepam was renewed multiple times without evidence of a physician's documented rationale for the extended duration. Facility staff confirmed the ongoing order and acknowledged the lack of compliance with the required documentation. Another resident with generalized anxiety disorder also had a PRN lorazepam order written for 30 days. Although the resident reported some anxiety and staff noted the medication was beneficial, there was no documentation from the physician providing a rationale for extending the PRN order beyond 14 days. The pharmacy's monthly review did not identify any irregularities or make new recommendations regarding this medication order.
Plan Of Correction
1. Medical records will be reviewed by providers and the Interdisciplinary Team (IDT) to determine the necessity of medication and frequency. Medications will be discontinued or frequency modified accordingly. All residents have the potential to be affected. 2. EMR Reports will be utilized to identify those with orders for PRN psychotropic medications. Behavior Management Program Policy was updated to include: "When pharmacological interventions are utilized, the duration of order must meet regulatory requirements. PRN psychotropic medications should not exceed more than 14 days unless clinical documentation by a provider is present to provide rationale. Orders will be reviewed during the Behavioral Health Committee meeting to ensure pharmacological interventions meet criteria for use and regulatory requirements." 3. Antipsychotic Medication Management policy was updated to include: "When pharmacological interventions are utilized, the duration of order must meet regulatory requirements. PRN Psychotropic medications should not exceed more than 14 days unless clinical documentation by a provider is present to provide rationale." Education will be provided to nurses, providers, and social services teams regarding policy updates and expectations. External partners providing pharmacy and behavioral health services will receive this refreshed education as well. Weekly Clinical Oversight meetings will monitor these medications utilizing EMR report on a weekly basis. 4. Behavioral Health Committee will review a report of all PRN psychotropic medications during monthly routine meetings to determine the necessity of medication and appropriate frequency. Medications will be discontinued or frequency modified accordingly. Weekly Clinical Oversight meetings will monitor these medications utilizing EMR report on a weekly basis. Five weekly audits to ensure compliance will be completed by Social Services or designee utilizing EMR report for the next 12 weeks. The executive director is responsible for compliance.