Avoiding medication errors and their adverse consequences is critical to achieving positive outcomes and reducing rehospitalizations. In this blog, I’ll explain how you can help prevent them – and an F332-333 citation.

F-Tag 332 says that facilities must be free of medication error rates (including both significant and nonsignificant medication errors) of five percent or greater while F-Tag 333 states that centers must ensure residents are free of any significant medication errors.

The Centers for Medicare & Medicaid Services defines a medication error as the observed preparation or administration of drugs or biologicals which is not in accordance with: physician’s orders, manufacturer’s specifications (not recommendations) or accepted professional standards and principles regarding the preparation and administration of the drug or biological.

A “significant medication error” means one which causes the resident discomfort or jeopardizes his or her health and safety. Since the relative significance of medication errors is a matter of professional judgment, these three general guidelines assist in determining whether a medication error is significant:

  • “Resident Condition” — The resident’s condition is an important factor to take into consideration. For example, a diuretic erroneously administered to a dehydrated resident may have serious consequences, but if administered to a resident with a normal fluid balance may not.

  • “Drug Category” — If the drug requires titration to a specific blood level, a single medication error could alter that level and precipitate a reoccurrence of symptoms or toxicity.

  • “Frequency of Error” — If an error is occurring with frequency, there is more reason to classify the error as significant.

In November 2014, CMS issued an updated State Operations Manual revision with new guidance on F332-333, including the following examples of medication errors:

  • Failure to flush before and in between each medication administration via enteral feeding tube is considered a single medication error and would be included in the medication error rate calculation. An exception would be for a resident who requires fluid regulation, in which case the physician’s order should include the amount of water to be used for flushing and administration of meds.

  • Failure of making contact with the conjunctival sac when administering eye medications so that the medication remains in contact with the eye for a sufficient period of time (3 to 5 minutes) before instillation of the next drop.

  • Failure to follow the administration instructions found in the manufacturer’s product information for metered dose inhalers (MDIs).

To identify potential problems with your drug administration and remain citation-free, ensure your nursing staff:

  • Confirm the identity of the patient before administration.

  • Know what drugs, in what strength and dosage forms, are being administered by identifying the product by its size, shape, and color or by observing the label.

  • Compare the medication and dosage schedule on the resident’s medication administration record (MAR) with the label and check the physician’s orders for inconsistencies.

  • Administer the medication following the most recent written order of the physician. If there’s a question about a medication order based on the resident’s diagnoses or conditions, call the provider pharmacy or the prescriber for clarification.

  • Have the person who prepares the dose administer the dose.

For additional assistance with medication accuracy, PharMerica’s consultants can help with mock and pre-survey audits, med-pass observations, cart audits, med room inspections and staff training and education.

In my next post, I’ll address F-Tag 329 and how to best avoid citations so you can better prepare to succeed.

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