Revised SOM guide for surveyors bolstering role of consultant R.Ph.s

January 14, 2008

Consultant pharmacists applaud CMS' guidelines on nursing home surveyors one year after State Operations Manual guidelines become effective.

The survey tags include tag F329, covering unnecessary medications; tag F425, covering pharmaceutical services; tag F428, covering medication regimen review; and tag F431, addressing storage, labeling, and controlled medications. (See Drug Topics, Jan. 24, 2005 and Dec. 11, 2006.)

How have the new requirements changed the practice of consultant pharmacists?

Losben praised the medication regimen review guidelines, stating, "Before [the new guide], the physician would always have to answer Yes or No to a consultant pharmacist's recommendation. Now, if the physician disagrees with the consultant pharmacist's recommendation, the burden is on the physician to comment on why he/she is disagreeing. Now there is true dialogue between the physician and the pharmacist-a more interactive role that makes them both part of the pharmaceutical care process."

Commenting on the tag covering unnecessary medications, Losben said, "The emphasis is on preventing adverse drug reactions and being able to recognize these reactions as soon as possible-to create not only a good atmosphere for pharmaceutical care but a safe one."

Gene Memoli, R.Ph., president-elect of the Connecticut chapter of the American Society of Consultant Pharmacists (ASCP), echoed Losben's sentiments. "The guide has increased consultant pharmacists' involvement in providing care to patients. If patients have a change in condition when they are in a nursing home for less than 30 days or have a change of condition that may be affected by the medication they are on, an interim medication regimen review (IMRR) has to be done within 72 hours of the event. You don't want the condition to continue to deteriorate and not have a pharmacist look at their drug regimen. You want them to act on it quickly so that the prescribers can make a change. This gets the consultant pharmacist more involved as part of the clinical team with the prescribers. This enhances the consultant pharmacist's value and role."

Losben credited the guidelines with forestalling many adverse drug events. "It's not just that a resident might become dizzy but that he or she may fall and break a leg, and that will affect the total well-being of that resident in a more permanent fashion. It has really put into place some mandate for the nursing facility to know about the medications-with the assistance of the pharmacist-and to continually monitor what seniors might be at risk for when they use multiple medications. It allows the consultant R.Ph. to be a leader in adverse drug reactions and in preventing adverse drug consequences."

Losben said the tag for labeling, storage, and security of medications helps to establish a chain of custody in the nursing facility. "It makes sure the drugs that are delivered are appropriately distributed and accounted for and that there are periodic reconciliations done. It really minimizes drug diversion and allows the nursing facility to identify it as soon as they possibly can through this reconciliation process."