One of the areas often cited under Pharmaceutical Services during survey is Unnecessary Drugs, which now falls under F757 in the updated State Operations Manual (SOM). The F-Tag states that “Each resident’s drug regimen must be free from unnecessary drugs”.

The term Unnecessary Drug is often misunderstood, incorrectly used and poorly applied. Upon hearing it for the first time, most assume that it refers to using a medication without an appropriate diagnosis. Although using a medication without an appropriate diagnosis would be considered unnecessary, a diagnosis alone does not justify the use of any medication or keep it from being unnecessary.

The Centers for Medicare and Medicaid (CMS) define an Unnecessary Drug as any drug used in excessive dosage (including duplicate drug therapy); for excessive duration; without adequate monitoring; without adequate indications for its use; in the presence of adverse consequences which indicate the dose should be reduced or discontinued; or any combinations of the above. As you can see from the list, there are many possibilities that could lead to a citation for an Unnecessary Drug. In the next section, we talk about some common examples encountered in everyday practice.

ACTION ITEM: Is your pharmacist alerting you to potential Unnecessary Drug compliance issues? When in doubt, ask your pharmacist if a medication may be considered unnecessary by surveyors.