Failure to Ensure Timely Provider Response to Pharmacist Drug Regimen Review and Gradual Dose Reduction Recommendations
Penalty
Summary
The facility failed to ensure that monthly drug regimen reviews (MRR) and gradual dose reduction (GDR) recommendations made by the consulting pharmacist were consistently and timely addressed by the attending providers for multiple residents. In several cases, the pharmacist identified the need for GDRs for psychotropic and other medications, but the facility was unable to provide documentation that these recommendations were reviewed or acted upon by the prescriber. For example, for one resident with moderate cognitive impairment receiving antidepressant medication, the facility could not produce documentation of a provider's response to a GDR recommendation made in September, and only provided a response dated much later, after repeated requests. Other residents with varying degrees of cognitive impairment and complex medication regimens, including antipsychotics, antidepressants, anxiolytics, and hypnotics, also had GDR recommendations from the pharmacist that were not addressed in a timely manner or lacked provider rationale when GDRs were declined. In some instances, the pharmacist had to repeat GDR requests due to lack of response, and the facility's own documentation confirmed that GDRs for certain residents were not addressed for multiple months. Interviews with facility staff, including the DON, revealed that there was an ongoing issue with providers not documenting rationales for declining GDRs and that unresolved GDRs were sometimes escalated to the medical director or nurse practitioner. Facility policies required that any drug regimen irregularities identified by the pharmacist be reported in writing to the provider, medical director, and DON, and that the provider's response, including rationale for no change, be documented in the medical record. Despite these policies, the facility did not ensure that provider responses to pharmacist recommendations were consistently documented, nor that rationales for declining GDRs were provided, resulting in a deficiency related to the management and oversight of unnecessary medications.