Long-Term Care Survey Alert

SURVEY NEWS

If you think surveyors have to observe med preparation and administration before they can write you up for a significant med error, you may be in for a survey surprise. A new Survey & Certification letter revises current interpretive guidance in the State Operations Manual that says surveyors have to make that observation before citing "significant medication errors." Surveyors determine whether an error is significant based on the resident's condition, the drug category and the error's frequency. The letter revises the guidance, clarifying that nursing home surveyors can cite a significant med error at F333 based on either resident review and/or observation of medication preparation or administration. New survey guidance for unnecessary medications will reflect the clarification.

Check out the examples: The memo cites three scenarios where surveyors would not have to observe med pass to cite a significant error. One involves a family's complaint to the ombudsman that the resident received the wrong dose of Synthroid over a period of 10 days, requiring hospitalization.  Surveyors will continue to cite at F332 any "significant medication error" that occurred at a 5 percent or greater frequency. But "any significant medication error included in the F332 (5 percent or greater) citation should also be cited at F333," according to the memo.

Read the memo at
www.cms.hhs.gov/SurveyCertificationGenInfo/downloads/SCLetter06-30.pdf.

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