Failure to Document Rationale for Not Following Pharmacist Medication Recommendations
Penalty
Summary
The facility failed to act upon the recommendations made by the consultant pharmacist during the monthly medication regimen review (MRR) for two residents. In both cases, the attending physician or nurse practitioner did not provide a documented rationale in the medical record for disagreeing with the pharmacist's recommendations, as required by facility policy. This lack of documentation was observed in the records and confirmed through staff interviews. For one resident, who had diagnoses including vascular dementia, Parkinsonism, anxiety disorder, and delusional disorder, the pharmacist recommended discontinuing Seroquel (an antipsychotic medication) unless a clear therapeutic benefit was documented. The physician disagreed with the recommendation but did not provide any rationale or justification in the resident's chart. Interviews with the ADON, DON, and Administrator confirmed that the expectation was for a rationale to be documented, and this was not done. In the second case, another resident with multiple diagnoses including vascular dementia, Parkinson's disease, generalized anxiety disorder, and a history of falls, was identified by the pharmacist as being at increased risk for falls and confusion due to several medications listed on the Beers Criteria. The pharmacist recommended discontinuing certain medications and implementing gradual dose reductions for others. The nurse practitioner responded to the recommendations by noting that a sitter had been provided for the resident, but did not address the specific medication recommendations or provide a detailed rationale for not following them. The DON and Administrator both acknowledged that the response was inadequate and did not meet facility expectations for documentation.