Key Implementation Concepts for Drug Regimen Review

Three new items have been added to Section N of the MDS, that will have a major impact on the policies and processes you have used in the past regarding medication reconciliation and administration.

  • N2001: Drug Regimen Review (Assessed on Admission)
  • N2003: Medication Follow-up (Assessed on Admission)
  • N2005: Medication Intervention (Assessed on Discharge)

Although this new item may seem to be commonplace in your facility already, there are scenarios which frequently arise, that may interfere and render your processes inadequate. These fundamental concepts will be required for Medicare Part A covered residents but are considered a best practice for any payer source.

  1. Knowledge is power! Begin by obtaining the current list of medications prescribed for the resident upon admission, including medications prescribed at the previous care setting (i.e., Hospital), and medications taken at home prior to admission. Many hospitals are only utilizing medications to treat the admitting condition, and not all previous medications are being administered.
  2. Analyze the medications, including OTC (over the counter) medications, vitamins, herbals, homeopathic, oxygen and TPN, etc. for duplicates, potential interactions, or potential adverse effects. Drug-to-food issues should be reviewed as well.
  3. Identify whether any potentially clinically significant medication issues (PCSMI) exist.
  4. Communication is essential! Discuss any issues with the physician, or extender, prior to midnight the next calendar day. Remember, this will be an ongoing deadline- before the clock strikes midnight!
  5. Complete any prescribed recommendations or corrections the physician, or extender, may make by that same timeframe of midnight the day following the identification of the PCSMI.
  6. Be sure to document the communication with the physician, or extender, in the medical record, including the date and time of the completion of the DRR process and any recommendations, including if no action is to be taken. 
  7. Continue to monitor medications throughout the resident’s stay to identify any additional PCSMI and communicate the findings with the physician, or extender timely. Recommendations, if any, should be completed by midnight of the next calendar day. This will be needed to report accurately at the end of the Medicare stay.

This process requires you to collect, examine, analyze and communicate continually, throughout the resident’s time at your facility. Something to consider, beginning today, if a resident is admitted on a Friday and discharged on Monday their discharge process is expected to have been completed. Do you have a process to handle weekend admissions and late-night admissions? Have you educated your staff on this process?

Looking for a Drug Regimen Review policy? Contact Celtic Consulting today for your complimentary copy at [email protected].

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