Leadership Considerations: F758-Psychotropic Drugs

The Pharmacy Services section of Appendix PP contains all Pharmacy Services requirements and interpretive guidelines (IG) found within the following regulatory sections and tags:

• §483.45(a) and (b)(1)-(3), F755—Pharmacy Services
• §483.45(c)(2), (4), and (5), F756—Drug Regimen Review
• §483.45(d)(1)-(5), F757—Unnecessary drugs
• §483.45(c)(3) and (e), F758—Psychotropic drugs
• §483.45(f)(1), F759—Medication errors [not 5 percent or greater]
• §483.45(f)(2), F760—Medication errors [significant medication errors]
• §483.45(g) and (h)(1) and (2), F761—Labeling and Storage of Drugs and Biologicals

Nationally, there is a decrease in the use of antipsychotic medications in nursing homes. In fact, the most recent report posted in October 2020 referenced that nationally there is a 41% decrease in the prevalence of antipsychotic use from 2011 through the second quarter of 2020. The reduction in antipsychotic use demonstrates the commitment of providers to improve the quality of life of vulnerable residents.

Recent OIG Issue Brief
In May 2021, the Office of Inspector General (OIG) issued a brief referencing that the Minimum Data Set used to calculate antipsychotic use may not accurately represent the number of residents receiving antipsychotic medications. The inconsistency is possibly incorrect data entered on the MDS or residents excluded from the calculation because of an active diagnosis of schizophrenia, Tourette Syndrome or Huntington’s Disease.

The OIG also noted discrepancies between the Medicare Part D drug claims, the Minimum Data Set, and the Medicare Service claims. In fact, upon review of MDS data, it was found that nearly one in three residents reported in the MDS as having schizophrenia did not have any evidence of this diagnosis in their Medicare claims history.

Also, the OIG recommended that CMS take the appropriate steps to validate and substantiate the use of antipsychotic medications prescribed to residents in nursing homes.

CMS could increase its targeted oversight of nursing homes that submit MDS data that are inconsistent with Medicare claims data, seem inconsistent with peer nursing homes or meet thresholds that might warrant follow-up.

Leadership Considerations:

• Clinical leaders should review the recommendation provided by OIG to identify potential impacts for their organization.
• Utilize this information as an opportunity to collaborate with the Medical Director and the Interdisciplinary Team committee to examine the administration of antipsychotic medication in the facility.
• Provide ongoing education and training to support staff competency surrounding accurate and proper documentation of psychotropic drug use.

Pathway Health’s team of experts is available to support your organization. Contact us to learn more.

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Resources:
Centers for Medicare and Medicaid Services (2020). “The National Partnership to Improve Dementia Care in Nursing Homes: Antipsychotic Medication Use Data Report [Online] Accessed June 2021 via the Web at Antipsychotic Use Data Report (cms.gov)

U.S Department of Health and Human Services (2021). Office of Inspector General: Issue brief OEI-07-19-00490 [Online] Accessed June 2021 via the Web at CMS Could Improve the Data It Uses to Monitor Antipsychotic Drugs in Nursing Homes, OEI-07-19-00490 (hhs.gov)

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