Report Reviews Survey Practices Around F-329 Unnecessary Medications Deficiencies

A recent 3-part report by Consumer Voice Leadership Council members, “Examining Inappropriate Use of Antipsychotic Drugs” examines how several states cite antipsychotic drug deficiencies during both traditional and Quality Indicator Surveys (QIS). Overall findings from the report include:

  • The states in the study all evaluated antipsychotic drug deficiencies very differently, including within different areas of the state. However, almost universally (95% of the deficiencies in this report), the deficiencies are cited at a D (isolated/no harm) or E (pattern/no harm), regardless of the actual severity.
  • F-329 deficiencies are cited at a high scope/severity if they are found as a result of a complaint survey rather than during recertification surveys – mostly Gs.
  • Even though federal survey protocol exists, the surveyors in this study were found to evaluate, discuss and document antipsychotic drug deficiencies in many different ways. Differences included the length of the information put in the SOD, whether the facility provided justification for use of the drug, and whether monitoring was in place for the resident’s specific behaviors that warranted the use of antipsychotics.
  • Some of the states in the report cited antipsychotic drug related deficiencies under F-222 Chemical Restraints. There was an even split between these being found on recertification surveys versus complaint surveys.

Several recommendations were made in an effort to provide suggestions on how to improve antipsychotic drug citations. First and foremost, they recommend more time be given to surveyors to conduct survey-related activities, and to give them more training so they are better able to identify these errors. They recommend that providers increase their staffing levels and complete more staff training. Additionally, they recommend the implementation of a mandatory Antipsychotic Drug/Dementia Care Report. This report would be sent to CMS, and would be required to be filled out and signed off on by the facility’s interdisciplinary team and include information on the resident’s diagnosis, all non-pharmacological interventions, consents, recommendations and physician responses to gradual dose reductions.

Part 1 of this report: How Seven States Cite Antipsychotic Drug Deficiencies can be accessed here.

Part 2 of this report: How Surveyors Describe How, When, and Why They Cite Antipsychotic Drug Deficiencies can be accessed here.

Part 3 of this report: Recommendations can be accessed here.


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