Failure to Document Physician Rationale for Pharmacy Recommendation
Penalty
Summary
The facility failed to act upon a consultant pharmacist's recommendation during the monthly medication regimen review for a resident with diagnoses of depression, anxiety, and pain. The pharmacist identified elevated creatinine levels and low hemoglobin in the resident's laboratory results and recommended considering discontinuation of Celebrex due to potential renal or gastrointestinal involvement. The physician responded to the recommendation by declining to discontinue the medication but did not provide a rationale for this decision, as required by facility policy. Documentation in the resident's electronic health record and care plan confirmed ongoing administration of Celebrex despite the pharmacist's concerns. Interviews with facility staff revealed a lack of understanding regarding the requirement for physicians to document a rationale when not following pharmacy recommendations. The administrative nurse and pharmacy consultant both indicated that a rationale was only necessary for gradual dose reductions of psychotropic medications, not for other pharmacy recommendations. The facility's drug regimen review policy, however, required an appropriate response from physicians concerning previous drug regimen review recommendations or drug irregularities, which was not met in this case.