Failure to Document Rationale for Declining Pharmacist Medication Recommendations
Penalty
Summary
The facility failed to ensure that the physician or prescriber documented the rationale for declining pharmacist recommendations during the monthly medication regimen review (MRR) for two residents who were receiving unnecessary medications. For one resident with a history of GERD, the pharmacist recommended a dose reduction of a proton pump inhibitor (PPI) and requested documentation of the necessity for continued use. The prescriber responded with 'No change' but did not provide a rationale for declining the recommendation, and the form lacked any explanation for the decision. In another instance, the pharmacist again recommended a review and possible reduction of the PPI, but the documentation was incomplete, with no length of time specified for continued therapy and no rationale provided for declining the recommendation. For a second resident, the pharmacist made recommendations regarding the use of multiple psychotropic medications, including the need for reassessment of PRN meclizine after 14 days and a gradual dose reduction (GDR) of psychotropic drugs as per federal guidelines. The prescriber responded with 'No change at this time after assessment: risk vs benefit,' but did not document any further information or rationale on the provided forms. Additionally, there were no progress notes addressing the use of meclizine or the symptoms it was prescribed for during the relevant months. Interviews with facility staff revealed that the DON managed the MRRs and did not request clarification or additional information if the provider marked a response. The ARNP involved stated that they were not initially educated about the requirement to provide an explanation when declining pharmacist recommendations. Review of the facility's policy confirmed that providers are required to document in the resident's medical record that the identified irregularity has been reviewed and what action, if any, has been taken, but this was not consistently done.