The Centers for Medicare and Medicaid Services (CMS) launched an initiative in early 2012 to improve dementia care in skilled nursing facilities and assisted living facilities nationwide through a combination of better reporting and technical assistance; increased public awareness; regulatory oversight; and enhanced education and outreach.

Building upon the CMS initiative, the American Health Care Association (AHCA) and the National Center for Assisted Living (NCAL) challenged members to safely reduce the off-label use of antipsychotic drugs by 15% by December 2012. When you consider that 80% of antipsychotic medications prescribed in skilled nursing and assisted living facilities are prescribed for off-label use such as behavioral conditions, reducing the use became a daunting task.

I recently hosted a webinar on the topic to explore the critical importance of proper documentation and monitoring as well as implementing a quality staff training solution. Consider that 25.2% of nursing facility residents receives antipsychotic medications, according to CMS. In order to meet reduction levels, providers need to convey to staff that antipsychotic medications should be used only as a last resort.

Tag F329 mandates that a resident’s drug regimen must be free from unnecessary drugs. Further, it specifically it states that antipsychotics cannot be given unless it’s necessary to treat a diagnosed condition, and that gradual dose reductions and behavior interventions are proposed.

Get Ready for the Surveyor!

The off-label use of antipsychotic medications can lead to significant penalties at survey time. Now more than ever, surveyors will be scrutinizing antipsychotic drug use and will look for and ask your staff about the following:

  • The effect on the resident involved: Changes in behavior, side effects, risk factors, etc.
  • Non-pharmacological approaches: Were any attempted? Were they successful?
  • Efforts to minimize the need for, reduce the dosage of, and/or reduce the duration of the medication

When surveyors look at unnecessary medications and off-label antipsychotics, a properly trained and educated staff may be the difference between a good or bad survey. Surveyors will want to ensure your staff is properly assessing the need for these medications and that they took steps to address behaviors prior to initiation of antipsychotics. The only way your staff can do that is if they are trained on how to identify the meaning behind a resident’s behavior. Your staff needs to understand their role in your facility’s initiative to reduce the use of antipsychotic medications.

Your staff will ultimately need to change the way they perceive a resident’s behavior and try to find alternative ways to address the behavior without defaulting to antipsychotic medications.

Cheryl Swann, RN-BC, BSN, WCC, LNHA

Cheryl Swann, RN-BC, BSN, WCC, LNHA has worked in long-term care for 20 years. Mrs. Swann has worked in many positions including Director of Nursing, Medicare Nurse Coordinator and Nursing Home Administrator. Cheryl is certified in both Gerontological nursing and wound care. In the past, she has assisted in the operations of multiple nursing facilities, including staffing, payroll, public health concerns, family member issues, management of consultant relationships (e.g. pharmacy, dietary, etc.), and as an intermediary between long-term care facilities and doctors. Mrs. Swann worked closely with federal monitors and the Office of Inspector General in developing an effective Continuous Quality Improvement and compliance program in her organization. Mrs. Swann has presented nationally regarding effective Quality Assurance, Restraint Reduction, Wound Prevention, CMS Five Star Quality Rating System and Developing a Corporate Compliance Program. Her expertise includes staff training and development, Quality Assurance and Performance Improvement initiatives, and policy development.

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