It is at the discretion of the PALTC team to use this implementation guide to optimize resident-centered medication management during the COVID-19 pandemic and beyond. Please note that this implementation guide is not intended to provide legal advice and its use is completely voluntary.
Optimizing the use of medications in an evidence-based, person-centered care approach is consistent with the recently enacted Quality Assurance Performance Improvement (QAPI) regulations (F865) and longstanding regulations related to unnecessary drugs (F757). Goals of the implementation guide include reduction of unnecessary drugs and aligning medication administration times, which can lead to a reduction in the potential for adverse events, drug interactions, resident burden, infection transmission risk, and time spent by nurses on medication pass.
Regarding consolidation of medication doses into appropriate schedules, provided that exact times are not included in and required for a medication order (i.e., give at 9 am and 5 pm), then by policy the PALTC facility can direct the administration schedule. Justification is provided by F759 (medication error rate) and F760 (significant medication errors), as noted: “To determine the scheduled time, examine the facility’s policy relative to dosing schedules. The facility’s policy should dictate when it administers a.m. doses, or when it administers the first dose in a 4-times-a-day dosing schedule.”
Residents have the right to choose health care schedules consistent with their interests and preferences, and the nursing home should gather this information in order to be proactive in assisting residents to fulfill their choices. The adjustment of medication administration times to meet the individual needs and preferences of residents must be considered by the care team. However, medication administration scheduling must still consider the physician/NP/PA prescription, manufacturer’s guidelines, and the types of medication, including time-critical medications. Some medications require administration within a narrow window of time to ensure resident safety or achieve a therapeutic effect while other medications are not affected by a more flexible schedule. Where appropriate, liberalizing the medication pass is clearly consistent with the cornerstone of the overriding principle of person-centered care. The guidance under F759/760 outlines a balanced approach, setting the expectation that the clinical team evaluates the appropriateness of each medication being considered for liberalized administration in the clinical setting of each individual resident.
Regulations referenced above can be found at: https://www.cms.gov/Medicare/Provider-Enrollment-and-Certification/GuidanceforLawsAndRegulations/Downloads/Appendix-PP-State-Operations-Manual.pdf.