Failure to Ensure Proper Physician Participation and PRN Psychotropic Medication Review
Penalty
Summary
The facility failed to ensure that a licensed pharmacist performed comprehensive monthly drug regimen reviews with proper physician participation and documentation for several months. Specifically, for three out of six months reviewed, there was no clear evidence that physicians had reviewed, approved, or denied the pharmacist's recommendations. The documentation forms used were inconsistent, with missing or unclear columns for physician approval, and in some cases, it was not possible to determine who had approved the recommendations. The consultant pharmacist acknowledged the lack of clear documentation and could not provide an alternative method to demonstrate physician participation in the review process. Additionally, the pharmacist failed to identify and address the use of as-needed (PRN) Ativan orders without a documented duration of use for three residents. For these residents, orders for Lorazepam (Ativan) were open-ended, lacking stop dates or documented rationales from physicians to extend the medication. The pharmacy reviews did not include recommendations regarding these PRN psychotropic medication orders, despite facility policies and pharmacy suggestions indicating the need for 30-day stop dates for such medications. The records for the affected residents showed ongoing administration of PRN Lorazepam without appropriate physician documentation or pharmacy intervention. Care plans indicated that the pharmacist was responsible for medication review, but there was no evidence of recommendations or follow-up regarding the continued use of these psychotropic medications. The deficiency was identified through review of records, pharmacy documentation, and interviews with the consultant pharmacist.