Regulatory Guidance Changes Affecting Medications in SNFs

Although the Centers for Medicare and Medicaid Services (CMS) Phase 3 updated nursing home Requirements of Participation have been in effect since 2019,  guidance was not released until the very end of June 2022, putting survey enforcement largely on hold until October 24.

Among the many revisions, the new guidance affects several medication-related topics. Long-term care pharmacies have been working with facilities to understand the implications of these changes, which  are listed below. For a detailed tip sheet, click here.

• Drug Regimen Free from Unnecessary Drugs (F-757/F-758 Facility Compliance) 
• Fentanyl Patch Disposal (F-755 Facility Compliance) 
• Gradual Dose Reduction (F-755 Facility Compliance) 
• Misdiagnosis Related to Antipsychotics (F-755 Facility Compliance) 
• Psychosocial Harm Evaluation (F-758 Facility Compliance) 
• Substance Abuse (F-689 Accidents/Hazards/Devices)
• Unnecessary Psychotropic/PRN Use (F-758 Facility Compliance) 

CMS’s release also includes guidance on new arbitration requirements; oversight of nursing home complaints and facility-reported incidents; improving consistency across state agencies in communications to complainants; and clarifying the “reasonable person” concept and examples across different severity levels.