Conditions of Participation Management of Drugs and Biologicals- Best Practices
HospiScript Services A Catalyst Rx Company
Describe the requirements of the regulations and best
practices related to drugs and biologicals
Meeting the standard for drugs and biologicals
Drugs that are generally not cost effective
1st generation vs. 2nd generation antipsychotics
Introduction to Conditions of Participation
The Hospice Final Rule was published in the Federal
Register on June 5, 2008 and became effective December 2, 2008
Hospices had an additional 60 days for QAPI requirements
which went into effect on February 2, 2009
The new COPs are patient-oriented, founded on
evidence and standards of practice, and emphasize quality improvement and patient outcomes.
Medication therapy management (MTM) is emphasized
The outcome-oriented survey process emphasizes the hospice’s
Surveyors instructed to focus on patient health and safety and to look at
All conditions viewed relative to outcomes for the patient/family
Goals should reflect patient/family preferences
Evaluate each CoP in the most efficient manner possible
Surveyor considers interrelatedness of the regulations while evaluating
compliance through observations, interviews, home visits, and record reviews
responsibilities, more in depth knowledge about the regulations may be required
Hospice providers should develop a strategy to
remain compliant with the regulations all of the time
Survey readiness “flurry” is not productive
Compliance is not an EVENT, it is a PROCESS
Meeting Standard: 418.106 Drugs and Biologicals
The hospice must employ or contract with and
individual to assure that medications meet each patient’s needs
PBM or other company/individual that provides such
Internal resources that meet the standard
Pharmacist are not required to be a member of
Meeting Standard: 418.106 Drugs and Biologicals Who is qualified to assure that medications meet
the needs of the patient? 418.106 (1)(a) L 688
Hospices must confer with an individual with
education and training in drug management
Physicians who are board certified in palliative medicine
RNs and NPs who complete a specific hospice or palliative
The hospice must be able to demonstrate that the
person has specific education and training in drug management
Meeting Standard: 418.106 Drugs and Biologicals
A hospice that provides inpatient care directly in its
own facility must provide pharmacy services under the direction of a qualified pharmacist who is an employee of or under contract with the hospice. The provided pharmacist services must include evaluation of a patient’s response to medication therapy, identification of potential adverse drug reactions, and recommended appropriate corrective action.
If ordered verbally or via electronic
Must be given to nurse, NP, MD or pharmacist
What about orders left on a recording?
OK, but must be reviewed by a pharmacist
Be sure to leave all pertinent information
Pharmacy must have a signed order PRIOR
to dispensing unless “Emergency” order
Faxed, signed order may serve as the
original- no follow up prescription needed
MDs may order 60 day supply- pharmacy can
Allowed in Alabama- not in all states
Verbal order may be accepted by pharmacist
Order may only be for emergency supply- in
Prescriber must make the call, not his/her agent
MD must send follow up signed order to the
pharmacy within 7 days for emergency supply only
Pharmacy required to report to DEA if Rx not received
418.106 (c) Standard: Dispensing of Drugs
Have written policy that promotes dispensing
Maintain records of receipt and disposition of all
418.106 (d) Standard: Administration of Drugs
(1) The IDG must determine the ability of
patient and/or caregiver to self-administer drugs in the home setting
(2) In an IPU, meds can be given only by:
Nurse, MD, other- according to State law
The patient- upon the approval by the IDG
418.106 (e) Standard: Labeling, Disposing, Storing of Drugs
(1)Labeling- in accordance with current
(2) Disposing of controlled drugs (i) In
home setting- Hospice must have written P&P
(A) provide a copy of P&P to patient/family
(B) Discuss P&P with patient/family
(C) Document providing and discussing P&P
418.106 (e) Standard: Labeling, Disposing, Storing of Drugs
Disposing of controlled drugs (ii) In IPU,
hospice must dispose of drugs in compliance with hospice policy and State and Federal requirements and maintain records of receipt and disposition of drugs.
418.106 (e) Standard: Labeling, Disposing, Storing of Drugs
(3) Storing- In an IPU- no specific storage
(i) Drugs must be stored in secure area in locked
compartments. Only personnel authorized to administer drugs may have access to locked compartments
(ii) Discrepancies must be immediately investigated by the
pharmacist and administrator and where required, reported to the appropriate State authority.
A written account must be made available to State and
Federal officials if required by law or regulation.
Work with facility to include needed hospice
medications in the facility stat cabinet/ emergency kit
Hospice must maintain a coordinated agency-wide
program for surveillance, identification, prevention, control, and investigation of infectious and communicable diseases
Must be an integral part of the hospice’s QAPI program
Monitor work related employee illness and infections
Analyze them in relation to patient infections
Take appropriate actions when an infection or communicable
disease is present to prevent its spread among staff, patients, family and visitors
The hospice must provide infection control education to
employees, contracted providers, patients, and family members and other caregivers
Is hospice staff aware of infection control principles and
Do they demonstrate this knowledge during home visits?
During home visits ask the patient/family or other caregivers to
describe infection control education they have received
Ensure that you have an adequate “infection control nursing bag”
policy/procedure for hospice staff that visits patients in their home
Ensure that patient/family received education materials and training
about infection prevention and control in the inpatient and home setting
Consider adopting an annual infection control education update for
Promote infection prevention and control within the hospice organization
Display infection prevention and control posters
Support health promotion activities for hospice staff
Encourage hospice staff to obtain flu shots during flu season
Erytab 333- Generic- Enteric coated base- time released
Possible Unnecessary Expense for Antibiotics
Receive effective pain management and symptom control
Be involved in developing the plan of care
Choose his or here attending physician
Receive information about services covered under the hospice
Receive information about the scope and limitations of services
Use all agents available as appropriate
If we know that pain and suffering can be
alleviated, and we do nothing about it, then we ourselves become the tormentors.
Meeting Standard 418.54 (c) Comprehensive Assessment
Describe process for medication review, including how adverse effects
Describe process followed in patient/family is non-compliant
Describe how patients/families are educated about pain management
Describe how symptoms are assessed and re-assessed
Describe how a patient is monitored when a new medication is added or
the dose is altered or medication is d/c’d
Demonstrate that common side effects of medications were anticipated
Show that the medications the patient is currently taking are the same
418.54 (c)(6) Initial and Comprehensive Assessment – Medication Profile Review
A review of ALL prescription and OTC, herbal
and alternate treatments. Includes but not limited to identification of the following:
Actual or potential drug interactions
Drug therapy associated with laboratory monitoring
418.54 (c)(6) Initial and Comprehensive Assessment – Medication Profile Review
Drug profile must be completed within 5 days of
admission as part of the comprehensive and updated at least every 15 days or with a change in the patient’s status.
Nurses should document a full medication
profile, including OTC and herbal medications
Not required to document relationship of drug
therapy to terminal illness or related condition but encouraged to do so.
418.54 (c)(6) Initial and Comprehensive Assessment – Medication Profile Review
Best Practices for Performing a Medication Profile Review When obtaining a medication history, the nurse should:
Ask to look at all prescription bottles
Verify that medications are labeled correctly
Capture full dosing information for each medication
Best Practices for Performing a Medication Profile Review
Use probing questions to trigger the patient’s memory on what they
What do you take only when you need it?
Do you ever NOT take your medication and why?
Ask about OTC and herbal meds and nutritional supplements
Ask about meds not taken orally- inhalers, patches, creams, drops
Assess the health literacy and compliance potential of the
Best Practices for Performing a Medication Profile Review
Take steps to simplify the patient’s drug regimen
Consider non-pharmacological therapies
Use sustained release products if appropriate and cost effective
Use the fewest meds in the simplest form to achieve the therapeutic
D/C meds that are not effective or don’t meet goals of hospice care
Establish relationship of medication to terminal diagnosis
Best Practices for Performing a Medication Profile Review
On admission and with medication changes, a review of
the patient’s medications, allergies and medical conditions should be conducted to:
Assure accuracy and completeness of the order
Assess appropriateness of dose, route of administration, dosage
Identify previous allergic or adverse reactions to a previous
medication or one that is chemically similar
Identify drug-drug or drug-disease interactions or
Best Practices for Performing a Medication Profile Review
Verify that the medication is safe and effective and is the most cost
effective solution for the patient’s symptom
Assess symptoms to determine if it may be the result of an adverse
Ensure that the patient is not receiving inappropriate duplicate
Multiple medications for the same reason
Use one medication to treat multiple symptoms when possible
Suggest alternate routes of administration when appropriate
Medications that are generally NOT the most cost effective
Atypical or Second Generation Antipsychotics (SGAs) vs. Conventional Agents
Conventional Agents
What is CATIE? Clinical Antipsychotic Trials of Intervention Effectiveness
Phase I- Determine which meds provide best Tx Phase II- Help choose alternate med when 1st choice was not
Schizophrenia Study AD Study Compares Atypical and Conventional agents
Older agents generally performed as well as newer agents
EPS was not seen more frequently with older agents
On the whole, newer agents have no substantial advantage
Head to head drug comparisons
Antipsychotic treatment must be individualized Newer agents cannot always be replaced with older agents
FDA classified Dypyridamole as a desi drug
Only official indication is IV to conduct a stress test
BI introduced Aggrenox on the strength of clinical
trials that showed Aggrenox was better than placebo
Annualized sales of approximately $331 million for the
Examples of Medication-Related QAPI Projects Queries by drug or drug class
Meperidine or Propoxyphene- reduce the use of inappropriate
Antipsychotics- examine use in dementia and if non-pharm measures
Antibiotic- Infection control measures
Patients receiving routine opioids not on a bowel regimen
Patients receiving long acting pain meds with no PRN breakthrough
PRN meds ordered at the appropriate interval
Patients receiving long acting inhaled beta agonists with no rescue
AW is a 54 yo female with end stage pulmonary
Pain score 9/10 most of the time, 5-6 at best Complaining of “lung pain” Current medications
WC is a 73 yo male with lung cancer with
Uncontrolled general pain and leg pain
Current pain meds are Fentanyl 100mcg 4
patches every 48 hours, MSIR 60mg q 1 h prn BTP
Case Study - Recommendations and Follow Up
Recommend 30mg methadone q12h with 60mg
NSAID for bone mets Monitor for excessive sedation Liberal use of BTP medication encouraged Follow up in 24 hours x 3
Subsequent follow up in 4 days- pain improved to 1-2/10 Subsequent follow up in 1 & 4 weeks- one additional
The new COPs have a strong emphasis on appropriate
medication therapy management and monitoring
Hiring or contracting with an individual with special training in
Documentation of all medications on the drug profile
Minnesota Emergency Health Powers Act Report to the Minnesota Legislature 2003 Minnesota Department of Health February 14, 2003 Commissioner’s Office 85 East Seventh Place, Suite 400 P.O. Box 64882 Minnesota Emergency Health Powers Act February 14, 2003 For more information, contact: Commissioner’s Office Minnesota Department of Health 85 East Seventh Place, Sui
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