The “Mega Rule”

The “Mega Rule”

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 of Nursing and facility’s Medical Director.

ACTION ITEM: Have you developed a policy and procedure for addressing pharmacist recommendations?

Now in Phase 2, we are focused on two main changes, 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.

In this issue, we will focus on the PRN psychotropic medications and in the April issue, we will discuss antibiotic stewardship.

As noted in Phase 2, orders for PRN psychotropic medications must be limited to fourteen days. PRN psychotropic orders, excluding antipsychotics may be extended beyond 14 days if the attending physician or prescribing practitioner believes it is appropriate to extend the order and documents the rationale for the extended time period in the medical record and indicates a specific duration. For PRN antipsychotics, the attending physician or prescribing practitioner must first evaluate the patient to determine appropriateness before writing a new order.

ACTION ITEM: Do you have a process to ensure compliance with these requirements?

How we can help

Because compliance is an ongoing process, we will continue to provide you the latest information available. If you are unsure whether your program meets the guidelines or have questions, please contact us and we will help you put a plan in place to close any gaps in your current system or if necessary, help you develop and implement a compliant system.

Any health, medical or drug information on the Web Site is for informational purposes only. This information is not intended to be used, and you should not use it, as a substitute for obtaining professional healthcare advice, diagnosis or treatment. You should always seek the advice of your doctor, a pharmacist or other qualified healthcare provider for professional healthcare advice, diagnosis or treatment for any medical condition.