Failure to Document CMS-Approved Indications for Antipsychotic Use
Penalty
Summary
The facility failed to ensure that physicians provided appropriate Centers for Medicare and Medicaid Services (CMS) approved indications for the use of antipsychotic medications for two residents. In both cases, the medical records documented the use of antipsychotic medications for diagnoses such as mood disorder, dementia, and depression, none of which are CMS-approved indications for these medications in residents with dementia. The orders for antipsychotic medications, including Olanzapine and Quetiapine, repeatedly lacked a documented, appropriate rationale for use as required by CMS guidelines. For one resident with severe cognitive impairment, multiple orders for Olanzapine were issued over several months, each time citing mood disorder or dementia as the indication. The care plan and assessments noted the resident's significant cognitive and physical impairments, as well as the use of multiple psychotropic medications. Despite ongoing monitoring and care plan reviews, there was no documentation of a CMS-approved indication for the antipsychotic, nor was there evidence of a risk versus benefit analysis for its continued use. Another resident, also with severe cognitive impairment and a history of dementia and depression, was prescribed Quetiapine for agitation and later for depression. The consulting pharmacist identified that the indication for use was not approved, and although the order was changed to depression, there was still no physician-documented rationale for the use of the antipsychotic. Staff interviews confirmed that the diagnoses used were not appropriate indications for antipsychotic use, and the facility's own policy required that psychotropics only be used when necessary to treat a specific condition and after considering risks and benefits. The lack of appropriate documentation and rationale for these medications constituted the deficiency.