Finding Description
Based on record review and interview, the facility failed to ensure the physician/prescriber documented the rationale for declining the pharmacist's recommendations for 2 (Residents #33 and #53) of 5 residents reviewed for unnecessary medications and failed to ensure the nursing department responded to the pharmacist's recommendation in a timely manner for 1 (Resident #54) of 5 residents reviewed for unnecessary medications.
Findings include:
1) Review of Resident #33's consultation report showed a consultant pharmacist's recommendation dated 11/4/2024 that read, Comment: [Resident #33’s name] has received Cymbalta 30 mg [milligram] qd [once a day]; Alprazolam 0.5 mg qhs [every night at bedtime]; Trazadone 100 mg qhs. Recommendation: Please attempt a gradual dose reduction (GDR). Rationale for recommendation: Dose reductions should occur in modest increments over adequate periods of time to minimize withdrawal symptoms and to monitor symptom recurrence (e.g., GDR is attempted in 2 separate quarters, with at least 1 month between attempts, within the first year in which an individual is admitted on a psychotropic medication or after the prescriber has initiated such medication, unless clinically contraindicated)… Response Requested. Physician's Response… 1. Continued us in accordance with the current standard of practice and a GDR attempt at this time is likely to impair this individual's function or cause psychiatric instability be exacerbating an underlying medical condition or psychiatric disorder as documented below, or… Please provide CMS [Centers for Medicare and Medicaid Services] required patient-specific rationale describing why a GDR attempt is likely to impair function or cause psychiatric instability in this individual: [No rationale or reason was documented].
During an interview on 7/8/2025 at 1:25 PM, the Director of Nursing (DON) stated, The expectation is that they [physicians/providers] will provide an explanation or reason why they are not accepting the pharmacist's recommendation. In a perfect world, they provide an explanation, but that doesn't always happen, and they don't always respond to my requests.
Review of Resident #33's progress notes showed no notes from Advanced Practice Registered Nurse (APRN) #2 on or around 11/4/2025 regarding declined recommendation.
During an interview on 7/9/2025 at 10:55 AM, APRN #2 stated, “The medications listed on Resident #33's MRR [Medication Regimen Review] were managed by psych [the Psychiatric Physician/Provider], but that she did sign the MRR indicating rejection of the pharmacist's recommendations.
2) Review of Resident #53's consultation report showed a consultant pharmacist's recommendation dated 4/8/2025 that read, Comment: [Resident #53’s name] has an order for an opioid oxycodone acetaminophen 5/325 mg every 4 hours as needed for x 7 days, as the sole “as needed” analgesic. Recommendation: Please initiate an order for acetaminophen 650 mg every 6 hours as needed for mild or moderate pain. Document the maximum daily dose of acetaminophen from all sources based on product labeling and the clinical profile (e.g. maximum of 3 grams/24hr [hour] and clarify that the opioid oxy/APAP [oxycodone/acetaminophen] 5/325 mg every 4 hours PRN [as needed] therapy is “for severe pain”… Response Requested: Declined.” The form was signed by APRN #2 on 4/9/2025 with no rationale or reason documented.
Review of Resident #53's consultation report showed a consultant pharmacist's recommendation dated 4/8/2025 that read, “Comment: [Resident #53's name] receives Atorvastatin 40 mg daily. Recommendation: Please monitor a fasting lipid panel on the next convenient lab day and every 12 months thereafter. Response requested: Declined.” The form was signed by APRN #2 on 4/9/2025 with no rationale or reason documented.
During an interview on 7/9/2025 at 10:00 AM, the DON stated, The doctors will not give a reason.
During an interview on 7/9/2025 at 11:05 AM, APRN #2 stated, [Resident #53’s name] has a history of coronary heart disease and there is no reason to complete a lipid profile and his history is documented in the chart.
3) Review of Resident #54's consultation report showed a consultant pharmacist's recommendation dated 6/11/2025 that read, T: Nursing… Comment: [Resident #54's name] receives a medication containing an inhaled corticosteroid, Trelegy Ellipta. Recommendation: To reduce the risk of thrush, please update the order to include the directions: Rinse mouth with water after use. Do not swallow… Response Requested. Director of Nursing’s Comments: [blank]. The form was signed by the Assistant Director of Nursing (ADON) on 7/7/2025.
Review of Resident #54’s physician order dated 6/11/2025 read, Trelegy Ellipta Inhalation Aerosol Powder Breath Activated 100-62.5-25 MCG/ACT [microgram/activated clotting time] (Fluticasone-Umeclidinium-Vilanterol) 1 inhalation inhale orally one time a day for SOB [shortness of breath].” The order had no further instructions.
During an interview on 7/8/2025 at 12:38 PM, the DON stated, Usually when there are recommendations, they come in 48-72 hours when they are printed, addressed, and changed. They come to me, ADON, Charge Nurse [Staff G, LPN’s name], 3-11 supervisor [Staff H, LPN’s name]. I am not sure why it was not done earlier.
Review of the facility policy and procedures titled “Medication Regimen Review” with the last approval date of 1/15/2025 read, Applicability: This policy 9.1 sets forth procedure relating to the medication regimen review (MRR). Procedure . 7. Facility should encourage Physician/Prescriber or other Responsible Parties receiving the MRR and the Director of Nursing to act upon the recommendations contained in the MRR. 7.1 For those issues that require Physician/Prescriber intervention, Facility should encourage Physician/Prescriber to either accept and act upon the recommendations contained within the MRR, or reject all or some of the recommendations contained in the MRR and provide an explanation as to why the recommendation was rejected. 7.2 The attending physician should document in the residents' health record that the identified irregularity has been reviewed and what, if any, action has been taken to address it. 7.2.1 If the attending physician has decided to make no change in the medication, the attending physician should document the rationale in the residents' health record.”
Findings include:
1) Review of Resident #33's consultation report showed a consultant pharmacist's recommendation dated 11/4/2024 that read, Comment: [Resident #33’s name] has received Cymbalta 30 mg [milligram] qd [once a day]; Alprazolam 0.5 mg qhs [every night at bedtime]; Trazadone 100 mg qhs. Recommendation: Please attempt a gradual dose reduction (GDR). Rationale for recommendation: Dose reductions should occur in modest increments over adequate periods of time to minimize withdrawal symptoms and to monitor symptom recurrence (e.g., GDR is attempted in 2 separate quarters, with at least 1 month between attempts, within the first year in which an individual is admitted on a psychotropic medication or after the prescriber has initiated such medication, unless clinically contraindicated)… Response Requested. Physician's Response… 1. Continued us in accordance with the current standard of practice and a GDR attempt at this time is likely to impair this individual's function or cause psychiatric instability be exacerbating an underlying medical condition or psychiatric disorder as documented below, or… Please provide CMS [Centers for Medicare and Medicaid Services] required patient-specific rationale describing why a GDR attempt is likely to impair function or cause psychiatric instability in this individual: [No rationale or reason was documented].
During an interview on 7/8/2025 at 1:25 PM, the Director of Nursing (DON) stated, The expectation is that they [physicians/providers] will provide an explanation or reason why they are not accepting the pharmacist's recommendation. In a perfect world, they provide an explanation, but that doesn't always happen, and they don't always respond to my requests.
Review of Resident #33's progress notes showed no notes from Advanced Practice Registered Nurse (APRN) #2 on or around 11/4/2025 regarding declined recommendation.
During an interview on 7/9/2025 at 10:55 AM, APRN #2 stated, “The medications listed on Resident #33's MRR [Medication Regimen Review] were managed by psych [the Psychiatric Physician/Provider], but that she did sign the MRR indicating rejection of the pharmacist's recommendations.
2) Review of Resident #53's consultation report showed a consultant pharmacist's recommendation dated 4/8/2025 that read, Comment: [Resident #53’s name] has an order for an opioid oxycodone acetaminophen 5/325 mg every 4 hours as needed for x 7 days, as the sole “as needed” analgesic. Recommendation: Please initiate an order for acetaminophen 650 mg every 6 hours as needed for mild or moderate pain. Document the maximum daily dose of acetaminophen from all sources based on product labeling and the clinical profile (e.g. maximum of 3 grams/24hr [hour] and clarify that the opioid oxy/APAP [oxycodone/acetaminophen] 5/325 mg every 4 hours PRN [as needed] therapy is “for severe pain”… Response Requested: Declined.” The form was signed by APRN #2 on 4/9/2025 with no rationale or reason documented.
Review of Resident #53's consultation report showed a consultant pharmacist's recommendation dated 4/8/2025 that read, “Comment: [Resident #53's name] receives Atorvastatin 40 mg daily. Recommendation: Please monitor a fasting lipid panel on the next convenient lab day and every 12 months thereafter. Response requested: Declined.” The form was signed by APRN #2 on 4/9/2025 with no rationale or reason documented.
During an interview on 7/9/2025 at 10:00 AM, the DON stated, The doctors will not give a reason.
During an interview on 7/9/2025 at 11:05 AM, APRN #2 stated, [Resident #53’s name] has a history of coronary heart disease and there is no reason to complete a lipid profile and his history is documented in the chart.
3) Review of Resident #54's consultation report showed a consultant pharmacist's recommendation dated 6/11/2025 that read, T: Nursing… Comment: [Resident #54's name] receives a medication containing an inhaled corticosteroid, Trelegy Ellipta. Recommendation: To reduce the risk of thrush, please update the order to include the directions: Rinse mouth with water after use. Do not swallow… Response Requested. Director of Nursing’s Comments: [blank]. The form was signed by the Assistant Director of Nursing (ADON) on 7/7/2025.
Review of Resident #54’s physician order dated 6/11/2025 read, Trelegy Ellipta Inhalation Aerosol Powder Breath Activated 100-62.5-25 MCG/ACT [microgram/activated clotting time] (Fluticasone-Umeclidinium-Vilanterol) 1 inhalation inhale orally one time a day for SOB [shortness of breath].” The order had no further instructions.
During an interview on 7/8/2025 at 12:38 PM, the DON stated, Usually when there are recommendations, they come in 48-72 hours when they are printed, addressed, and changed. They come to me, ADON, Charge Nurse [Staff G, LPN’s name], 3-11 supervisor [Staff H, LPN’s name]. I am not sure why it was not done earlier.
Review of the facility policy and procedures titled “Medication Regimen Review” with the last approval date of 1/15/2025 read, Applicability: This policy 9.1 sets forth procedure relating to the medication regimen review (MRR). Procedure . 7. Facility should encourage Physician/Prescriber or other Responsible Parties receiving the MRR and the Director of Nursing to act upon the recommendations contained in the MRR. 7.1 For those issues that require Physician/Prescriber intervention, Facility should encourage Physician/Prescriber to either accept and act upon the recommendations contained within the MRR, or reject all or some of the recommendations contained in the MRR and provide an explanation as to why the recommendation was rejected. 7.2 The attending physician should document in the residents' health record that the identified irregularity has been reviewed and what, if any, action has been taken to address it. 7.2.1 If the attending physician has decided to make no change in the medication, the attending physician should document the rationale in the residents' health record.”