There were two important changes that took place when Phase Two of the CMS “Mega Rule” became effective on November 28, 2017: 1) limiting PRN psychotropic medication orders to 14 days and 2) implementing an Infection Prevention and Control Program (IPCP) that includes an Antibiotic Stewardship Program. Last month we discussed specific limits on PRN psychotropics. This month we will discuss antibiotic stewardship and what you must do to be compliant. CMS requires facilities to establish an infection prevention and control program (IPCP) that must include, at a minimum, an antibiotic stewardship program. The goal of the program is to...

At this point everyone has heard of the so-called CMS “Mega Rule” or the nursing home Requirements for Participation, and the resulting changes. On September 28, 2016, CMS issued the Mega Rule with a three-phase implementation. Phase 1 became effective on November 28, 2016. Phase 2 became effective on November 28, 2017, and Phase 3 will become effective on November 28, 2019. During Phase 1 we talked about the need for the pharmacist to perform a drug regimen review (DRR) for each resident at least once a month and for a report to be provided to the attending physician, Director...