by Donna Williams, RN, BS, MBA, CDONA/LTC

Often times, the importance of the role of the pharmacist as an active member of the interdisciplinary team is overlooked.  Most often, facilities excel at ensuring the physician and the responsible party is notified of a change of condition as required.  However, are you aware that there is also a regulation that requires that the pharmacist be notified of a change in condition as well?

Depending on your organizational policies, the definition of a “change of condition” may be very broad.  For example, an episode of emesis, constipation, weight losses or weight gains, or even a witnessed fall may all constitute a “change of condition” for the patient or resident.  How does your organization define a “change in condition?”  The need to notify the pharmacist with each of these types of events may be overwhelming to the staff as well as the pharmacist.

So in seeking clarification of the pharmacist’s role in the interdisciplinary team as it relates to changes in condition, I contacted Jeffrey Herr, Pharm D. and Sacramento Manager of Clinical Operations for PharMerica for more information related to potential deficiencies.  In summation of his information, pharmacy-related federal deficiencies may be issued under F-309, Quality of Care; F-425, Pharmacy Services; F-428 Drug Regimen Review, and California State regulation Title 22, § 72375 (c).

As it relates to the patients who experience a change in condition, the Summary provided by CMS in the most revision for 11-26-14 state that for F428, Drug Regimen Review, the MRR (Medical Record Review) requirement applies to each resident – including respite, hospice, short-stay and those who experience a change in condition.

This is an open topic.  How will your organization respond to this directive?  Conversations are continuing on how to best meet this intent of this regulation.

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