by Flora Brahmbhatt, Pharm. D., CGP

Beginning August 1, 2012, the California Department of Public Health will use a new tool to survey antipsychotic use in nursing homes. This 10-section tool will cover all areas with regards to antipsychotics including diagnosis, appropriateness of behavior monitors, documentation, and informed consent. This appears to be at least in part a result of recent nationwide and statewide reports indicating much inappropriate use of these medications, and statistics indicating that nationally, well over 20% of nursing home residents receive antipsychotic medication. With input from CALTCM, CAHF requested some modifications to this tool from the CDPH, but very little was changed. In many ways, this tool levels the playing field for facilities in understanding the exact expectation to be in compliance.

by Glenn Panzer, MD

Recently the DEA fined a pharmacy for prepopulating prescriptions for controlled substances.

It seems to have all started when a “whistle blower” from a Midwestern state reported that a pharmacy company was going too far in assisting doctors with phone orders for C-II medications by sending the physician a fax prescription with all the data, patient's name, address, date, Rx, amount dispensed and the sig filled in. Then all the doctor had to do was review, sign and fax back to the pharmacy company.  As the story goes the DEA found fault with this practice stating that the prescribing physician had to be the primary source of the information and that the pharmacy could only remind the doctor that a hard copy was required and doctor had to "populate all the fields."

John H. Fullerton, MD, CMD , MRO, FACP, AGSF, FAAHPM

As Co-Chair of CALTCM’s: Policy & Professional Services Committee (PPSC) [and as a member of AMDA’s Public Policy Committee (PPC)], I trust you find these episodic, 'Pulse-Like’ updates of the current agenda and status of CALTCM’s PPSC published by “The Wave” to be informative and helpful.

Our committee is currently actively refining CALTCM’s PPSC’s mission statement to not only remain internally regulatory compliant, but to more accurately reflect the true trans-disciplinary team composition of our state-wide constituency (emphasizing our corresponding “brain trust” and competitive advantage.)1   We plan to also be more forward-viewing to emphasize the importance of developing long-term strategic initiatives and strategic relationships.  We likewise plan to achieve functional integration with the relevant and valued positions of AMDA’s Public Policy Committee (PPC).

Only July 6 the DHHS Office of Inspector General (OIG) released a report indicating that 99 percent of of 375 nursing home records failed to meet one of more Federal requirements for resident assessment and or care plans for residents on antipsychotics. See for yourself by downloading the complete report.  I think that although this report does find some cases where important elements of process were not followed, the 99% figure is unnecessarily inflammatory as it represents a 99% incidence of the care plan not indicating the physician attended or participated in the interdisciplinary discussion, and documented their participation by signing the form. To the degree that this does NOT represent the common practice of physician participation in care planning, it leaves a very false impression. This masks the real issues of lacking quarterly assessments, failure to document RAPs for psychotropic drug use, etc. that do reflect a problem and of course were much less common than 99%. Many cases were identified of inadequate documentation of planned gradual dose reductions - that seems a more pertinent target of intervention that expecting that the attending physicians will attend each such care plan meeting rather than give their input through an agent such as the nurse. Why not download the report and use it as a tool in your facility's quality assurance meetings? At the least, it will trigger plenty of discussion!