Sonja Quale

Avoiding the administration of unnecessary drugs is critical to maintaining a resident’s highest practicable health and well-being, and the basis of F-329. 

According to CASPER, 21.6% of facilities were cited for a F-329 deficiency based on a March 1, 2016, report of data on the last standard health survey of active SNF/NF. That is the sixth highest in the number of citations. In this blog, I’ll share certain facility risk factors for F-329 citation by surveyors, particularly when it comes to use of the highly scrutinized antipsychotic drugs.

F-329 states that each resident must receive only those medications necessary, in the doses and for the duration required, to treat specified conditions after consideration of non-pharmalogical interventions. A resident’s drug regimen must be managed and monitored to promote his or her optimal mental, physical and psychosocial well-being, with particular attention paid to minimized adverse consequences or worsening symptoms.

In addition, F-329 states that antipsychotic drugs should only be given to residents who have adequate indication for its use, and that residents who use antipsychotic drugs must receive gradual dose reductions to determine if the indication for use can be managed at a lower dose or if the medication can be discontinued.

To ensure compliance with F329, a surveyor will seek to determine:

  • Whether a resident is taking only those medications that are clinically indicated in the dose and for the duration to meet his or her assessed needs,; if non-pharmacological approaches were attempted when clinically indicated; and if gradual dose reductions were made for antipsychotics

  • If comprehensive care plans reflect appropriate parameters for monitoring medications or mediation combinations that pose a risk of adverse consequences

  • If a facility’s medication management system monitors the effectiveness of medications and evaluates worsening signs or symptoms or change in condition that could be related to the medication

  • Whether the pharmacist performs monthly medication regimen reviews

  • How a center identifies and reports irregularities

Revisions to guidance in the State Operations Manual issued in 2016 highlight the importance of reducing the risk of psychosocial harm associated with noncompliance with specific regulations. Recommendations include:

  • Using non-pharmacological approaches for distressed behaviors

  • Focusing on identifying underlying causes of delirium, a common adverse consequence from medications, as well as other factors such as electrolyte imbalance and infection

  • Monitoring of psychosocial functioning that can result from a medication side effect

  • Watching for signs, symptoms or conditions that may be associated with medications, such as apathy, lethargy, and mental status changes

Moreover, significant additions to the guidance noted in the deficiency categorization section of F329 include:

  • Failure to recognize that symptoms of increased confusion and that newly developed inability to do activities of daily living resulting in hospitalization are the result of excessive doses of antipsychotic given without adequate clinical indication

  • Failure to recognize the continuation of an antipsychotic, originally prescribed for delirium, has caused significant changes in the resident’s behavior from baseline

  • Failure to re-evaluate continuation of an antipsychotic originally prescribed for acute delirium which resulted in significant side effects

In my next post, I’ll address F425 and how to avoid a citation so you can better prepare today to succeed tomorrow.

Sonja Quale, Pharm.D., is the vice president and chief clinical officer at PharMerica Corporation.