Survey practices around antipsychotic medications need to be updated, report says

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The Centers for Medicare & Medicaid Services should provide better surveyor training in understanding use of antipsychotic medications and reestablish a separate F-Tag for related deficiencies, according to a recently issued report.

The three-part document was released by Toby Edelman of the Center for Medicare Advocacy and Dean Lerner of Dean Lerner Consulting. Both are members of the Leadership Council of the National Consumer Voice for Long-Term Care.

Part I of the report analyzes deficiencies for off-label use of antipsychotic medications in nursing facilities and skilled nursing facilities in seven states. The analysis reveals certain patterns, such as that surveyors “almost always” categorize these deficiencies as causing no harm to the resident. This is the case even when the surveyors have documented resident harm, the authors contend.

The second part shares surveyor responses to a 49-question survey distributed in 10 states, with the assistance of CMS. More than 400 surveyors participated, sharing details about how and why they issue citations related to antipsychotic medication use, their suggestions for improving the survey process, and their impression of efforts to reduce inappropriate prescribing.

The 171-page section includes excerpts of survey responses and identifies patterns. For example, many responses indicated it is becoming more difficult for surveyors to access and understand information from the Minimum Data Set as electronic medical records become more common.

In Part III, the authors offer recommendations for how to improve the survey process. They argue that the questionnaire showed that most surveyors have a “sufficient awareness” of how to analyze antipsychotic misuse for severity and scope, yet the data from Part I showed problems with severity and scope levels in actual citations. To address this disconnect, surveyors should be given more time to complete survey activities and receive more support from state and federal offices, the report recommends.

Other recommendations include simplifying the State Operations Manual with clearer examples and more direct guidance on scope and severity. A separate F-Tag for antipsychotic drugs would also be a helpful tool, the authors argue. This would “unbundle” the issue from the more general “unnecessary drugs” tag currently in use.