Welcome back to the Ftag of the Week on the CMSCG Blog, your go-to spotlight for decoding the regulatory landscape of skilled nursing and long-term care. Each week (or sometimes more) we break down a specific Ftag from the CMS State Operations Manual, offering practical insights, survey trends, and actionable guidance to help providers stay ahead of compliance challenges. The CMSCG Ftag of Week series is designed to sharpen your understanding, support quality improvement, and reinforce your commitment to resident-centered care.
As you are likely aware, F605 is one of the regulations in State Operations Manual Appendix PP which had some significant changes that became effective at the end of April 2025. We waited to post an Ftag education series for F605 to give our readers some insight into how surveyors are citing F605 since the regulatory changes occurred and not miss this information due to a summer vacation. Be sure to review all the parts of this series, since we’ll be providing citation examples throughout the next posts.
F605 – Regulation & Overview
As always, we’ll review the regulation itself and then some of the definitions to get things started. For this tag, there’s a lot!
Free from Chemical Restraints
F605 requires that residents have the right to be treated with respect and dignity, including the right to be free from any chemical restraints which are imposed for the purposes of convenience or discipline and are not required to treat the resident’s medical symptoms.
“Chemical Restraint” means any drug used for discipline or staff convenience and not required to treat medical symptoms. Per SOM Appendix PP, this includes instances when psychotropic medication may be approved to treat certain symptoms, however nonpharmacological interventions should be used or attempted (unless clinically contraindicated) because they are less dangerous to the health and safety of the resident. Under those circumstances, the medication would not be deemed required to treat the resident’s symptoms because a safer alternative should be used.
That’s an important point for providers to understand. Appendix PP further provides an example that if a nonpharmacological intervention should be attempted or used and is not clinically contraindicated, but the facility administers a med instead, and that med has the effect of “convenience,” then the med would be considered a chemical restraint.
“Convenience” means the unnecessary administration of a medication that causes (intentionally or unintentionally) a change in the resident’s behavior which results in the resident being subdued and/or requiring less effort from staff. If a medication is administered which causes symptoms which are consistent with sedation, staff may not need to spend as much time addressing a resident’s behavioral needs, and therefore this would be “convenience.” Symptoms consistent with sedation include:
- Excessive sleeping
- Drowsiness
- Decreased activity
- Withdrawal
“Discipline” is any action taken by facility staff for the purpose of punishing or penalizing a resident, including administration of a medication.
“Medical Symptom” is a characteristic or indicator of a medical, physical or psychological condition.
Not sure you’ve got the current Ftag list?
Psychotropic Drugs
The regulatory guidance which was part of F758 was relocated to F605, so this also means that some of the regulations have been relocated. This is one of them.
SOM Appendix PP states that a psychotropic drug is any drug that affects brain activities which are associated with behavior and mental processes, and there are several types of drugs which are considered psychotropics.
Psychotropic drugs include drugs in the these categories:
The facility is required to ensure that, based on the resident’s comprehensive assessment:
- A resident who has not used psychotropic drugs are not given psychotropics unless they are necessary to treat a specific condition as diagnosed and documented in the clinical record
- Gradual dose reductions are attempted for residents using psychotropic meds to attempt to discontinue these meds. Behavioral interventions should also be used, unless clinically contraindicated
PRN Psychotropic Orders
The existing guidance for PRN psychotropic meds which has been in place for several years has also been moved to F605, but it’s an area where providers still have a difficult time. The regulations state:
- Residents do not receive PRN psychotropics unless the medication is necessary to treat a diagnosed specific condition that is documented in the clinical record
- PRN orders for psychotropic drugs are limited to 14 days.
- If a resident’s attending physician or prescribing practitioner believes that the PRN order should be extended beyond 14 days, the rationale must be documented in the medical record and a duration for the PRN order indicated.
- PRN orders for antipsychotics are limited to 14 days. In order for a PRN antipsychotic to be renewed, the resident must be evaluated by the attending physician or prescribing practitioner to ensure that the medication is appropriate.
Sign up for updates like these from CMS Compliance Group, Inc.
Get information delivered right to your inbox – sign up here!
Unnecessary Drugs
Not only did regulations from F758 get relocated, but language from F757 is also included under F605 now. F605 requires that each resident’s drug regimen must be free from unnecessary drugs. Any drug is considered “unnecessary” when it is used in any of the following ways:
- In excessive dose
- For excessive duration
- Without adequate monitoring
- Without adequate indication for use
- In the presence of adverse consequences which indicate the dose should be reduced or discontinued
- Any combination of the above
“Adequate indication for use” refers to the identified, documented clinical rationale for administering a medication. The rationale must be based upon an assessment of the resident’s condition and therapeutic goals, and after any other treatments have been deemed clinically contraindicated.
SOM Appendix PP states clearly: “For psychotropic medications, without documentation in the record explaining that the practitioner has determined that other treatments have been deemed clinically contraindicated, the indication for use is inadequate.”
The definition further states that medications must be administered consistent with manufacturer’s recommendations and/or clinical practice guidelines, standards of practice and other sources.
That’s the regulation in a nutshell – just wait until we get to all the Interpretive Guidance (IG) for F605. Check back for Part 2 shortly.
CMS Compliance Group, Inc. is a regulatory compliance and quality improvement consulting firm that works with post-acute providers throughout the United States. Learn more about our nursing home consulting services or contact us to learn more about how we can work together to achieve your organizational goals.
All content on this website is copyrighted and property of CMS Compliance Group, Inc.. Please refer to our Terms of Use before copying, reproducing, modifying, distributing or republishing any content on cmscompliancegroup.com.
