Failure to Ensure Proper Diagnosis and Regulatory Compliance for Psychotropic Medication Use
Penalty
Summary
The facility failed to ensure that two residents had appropriate diagnoses for the use of antipsychotic and antidepressant medications, and did not comply with regulations regarding the duration of PRN antipsychotic orders. For one resident with mild dementia, agitation, and brief psychotic disorder, a PRN order for Haldol was written for 60 days to manage agitation, without a proper diagnosis justifying its use for agitation and without adhering to the required 14-day stop date for PRN antipsychotics. The order was written by a Physician Assistant and hospice Physician, both of whom were unaware of the 14-day regulatory limit. The Consultant Pharmacist, who reviewed the order, did not question the extended duration or the diagnosis, assuming hospice orders were exempt, and the Director of Nursing stated that staff did not verify medication orders for accuracy or compliance with regulations. For another resident with unspecified dementia and no documented behavioral or psychotic disturbances, antipsychotic (olanzapine) and antidepressant (sertraline) medications were ordered and administered without a supporting mental health diagnosis. The resident's records and progress notes did not indicate behaviors or symptoms that would justify the use of these medications. The Physician Assistant and Assistant Director of Nursing confirmed that the medications were ordered for dementia without behaviors, and that no mental health diagnosis was present until after the deficiency was identified. The Director of Nursing acknowledged that the facility relied solely on pharmacy review for medication order accuracy and was unaware of the missing diagnoses until it was brought to their attention. These deficiencies were identified through record review and interviews with facility staff, the Consultant Pharmacist, and the prescribing clinicians. The facility's process lacked adequate checks to ensure that medication orders were supported by appropriate diagnoses and that regulatory requirements for PRN antipsychotic medications were followed.