In a new S&C letter for nursing homes, CMS provides updated guidance to assist surveyors with identifying psychosocial harm related to the use of unnecessary medications. There have been no changes to the regulatory language itself, but revisions include:
- Revision to Appendix PP of the SOM at F-329 to make it easier for surveyors to use and provide language that describes how psychosocial harm may be caused by unnecessary use of medications
- Revision of the Psychosocial Outcome Severity Guide in Appendix P
- Revision of several F-tags to assist surveyors with identifying the risk of psychosocial harm within the specific regulations
The revisions to the guidance at F-329 include updated medication tables and resources for surveyors on medication uses, side effects, adverse effects, drug classifications, and interactions. This type of guidance will assist surveyors with identifying many types of medications that could potentially be identified as “unnecessary,” including medication classifications like the ones that are being captured in the new Quality Measures such as anti-anxiety meds and hypnotic meds. Diligent facilities would have already been keeping in mind the 2006 guidance from CMS related to psychosocial harm, and these revisions make it even more important for facilities to have a grasp of how unnecessary medications can impact residents.
The revisions also include the addition of language that will assist surveyors with determining if there were negative psychosocial outcomes under the following F-tags:
- F-221 Right to be Free from Physical Restraints
- F-222 Right to be Free from Chemical Restraints
- F-223 Free from Abuse/Involuntary Seclusion
- F-224 Prohibit Mistreatment/Neglect/Misappropriation
- F-225 Investigate/Report Allegations/Individuals
- F-226 Develop/Implement Abuse/Neglect, etc. Policies
- F-241 Dignity and Respect of Individuality
- F-242 Self Determination – Right to Make Choices
- F-246 Reasonable Accommodation of Needs/Preferences
- F-248 Activities Meet Interests/Needs of Each Resident
- F-250 Provision of Medically Related Social Service
- F-310 ADLs Do Not Decline Unless Unavoidable
- F-320 No Behavior Difficulties Unless Unavoidable
- F-353 Sufficient 24 Hour Nursing Staff Per Care Plans
Read the March 25, 2016 CMS S&C Letter: “State Operations Manual (SOM) Surveyor Guidance Revisions Related to Psychosocial Harm in Nursing Homes,” (Ref: S&C: 16-15-NH).