As noted in earlier posts, there is significant Interpretive Guidance (IG) in Appendix PP regarding F759 and what constitutes a med error and how it is calculated. In Part 3 of our Ftag of the Week for F759 Med Error Rates of 5% or More, we will wrap up this regulation by discussing a few more areas where med errors can be potentially identified as well as begin discussing the difference between a med error and a significant med error. Significant medication errors have their own regulation (F760) and that will be reviewed in a future Ftag of the Week on the CMSCG Blog.
Metered Dose Inhalers
Metered dose inhalers present another potential area for a med error to be observed. Staff need to ensure that the medication is properly administered so the resident receives the appropriate amount of medication, which can present a problem, especially if a resident is unable to understand the instructions or participate. The goods news is that if a staff member follows the appropriate procedure, but the resident is unable to participate, then this would not be considered a medication error by a surveyor if it is an isolated incident. Where there is a potential for a medication administration error to occur is if staff continue to try to administer the inhaler with the same results because the resident’s condition does not allow the proper administration. At that point, the surveyor is going to investigate what alternative routes the staff has tried, if staff have communicated this issue to the physician or the consultant pharmacist to address the resident’s need.
If a resident cannot tolerate a sublingual medication and instead swallows it, staff should also alert the physician so an alternative medication can be provided. As noted above, if this happens as an isolated incident during observation, then that’s one thing, but if there is a pattern of inability to use the med without swallowing it, then surveyors are going to dig a little deeper.
Nutritional and dietary supplements are not considered medications, so noncompliance identified with nutritional or dietary supplement administration will generally not be included in a provider’s med error rate, with one category of dietary supplements considered an exception to that statement.
The category of dietary supplement that would be included in the med error rate is vitamins and minerals. Per the IG, herbal and alternative products are not considered dietary supplements since their composition varies based on the manufacturer, which prevents standardization, and additionally, they are they are not regulated by the FDA. So, an error would be considered only if a concern was identified related to vitamins or mineral administration.
Nutritional supplements, such as parenteral, enteral, or meal replacement products, are not considered medications as it relates to medication administration on survey, so issues with giving supplements would not be factored into the provider’s med error rate. However – don’t forget that just because these would not be considered med errors that they don’t matter. Failure to provide ordered nutritional supplements to residents can result in other potential negative outcomes, including unintended weight loss or contribute to skin breakdown/poor healing.
What Constitutes a Significant Medication Error?
In a prior post, we noted that the Interpretive Guidance for F759 & F760 Residents Are Free of Significant Med Errors are combined. The difference between a non-significant med error and a significant med error is based on whether a resident experiences discomfort or the error jeopardizes his or her safety. This should be based on the resident’s condition, the category of the drug and the frequency of the error. While we will look at F760 in another post, the IG states that that any significant medication error that is identified will be cited at F760, regardless of whether the med error rate is 5% or greater.
As you can see from the past couple parts of our Ftag of the Week, there are a significant number of areas where a medication error can be identified, and as such, this is a good time to remind facilities about the importance of competencies and conducting routine medication administration observations of staff responsible for medication administration. Following standards of practice will be more important than ever after focusing on infection control and COVID-19-related practices for the past couple years, as well as ensuring that new staff are following facility protocols.