Department of Health and Human Services 

OFFICE OF 

INSPECTOR GENERAL 

JANET REHNQUIST 

Inspector General 

NOVEMber 2001 

OEI-02-00-00490 

Psychotropic Drug Use 

in Nursing Homes 
OFFICE OF INSPECTOR GENERAL 

The mission of the Office of Inspector General (OIG), as mandated by Public Law 95-452, is to 

protect the integrity of the Department of Health and Human Services programs as well as the 

health and welfare of beneficiaries served by them. This statutory mission is carried out through a 

nationwide program of audits, investigations, inspections, sanctions, and fraud alerts. The 

Inspector General informs the Secretary of program and management problems and recommends 

legislative, regulatory, and operational approaches to correct them. 

Office of Evaluation and Inspections 

The Office of Evaluation and Inspections (OEI) is one of several components of the Office of 

Inspector General. It conducts short-term management and program evaluations (called 

inspections) that focus on issues of concern to the Department, the Congress, and the public. The 

inspection reports provide findings and recommendations on the efficiency, vulnerability, and 

effectiveness of departmental programs. 

OEI's New York regional office prepared this report under the direction of John I. Molnar, 

Regional Inspector General, and Renee C. Dunn, Deputy Regional Inspector General. Principal 

OEI staff included: 

REGION 

Demetra Arapakos, Project Leader

Patricia Banta, Lead Analyst

Miriam Gareau, Program Analyst

Thomas Zimmerman, Program Analyst

Robert Gibbons, Region IX

.

HEADQUARTERS 

Brian Ritchie, Director, Technical Support Staff

Bambi Straw, Program Specialist

Barbara Tedesco, Mathematical Statistician

To obtain copies of this report, please call the New York Regional Office at (212) 264-2000. 

Reports are also available on the World Wide Web at our home page address: 

http://www.hhs.gov/oig/oei 
EXECUTIVE SUMMARY 

PURPOSE 

To assess the extent and nature of inappropriate psychotropic drug use in nursing homes 

and how it relates to chemical restraints. 

BACKGROUND 

The Senate Special Committee on Aging requested that the Office of Inspector General 

look at the extent to which psychotropic drugs in nursing homes are being used as 

inappropriate chemical restraints. Usage rates for these drugs have been increasing since 

1995. A chemical restraint is the use of a drug to control an individual’s behavior and is 

legally appropriate only if used to ensure the physical safety of residents or other 

individuals. 

Psychotropic medications are drugs that affect brain activities associated with mental 

processes and behavior. They are divided into four broad categories: anti-psychotic; antidepressant; anti-anxiety; and hypnotic medications. The Centers for Medicare & Medicaid 

Services established guidelines for the appropriate use of these drugs in nursing homes. 

Several programs exist to monitor the quality of care in nursing homes, including the 

appropriate use of psychotropic drugs. These include the nursing home survey and 

certification process and the State Long Term Care Ombudsman program. 

We combined five methods for this inspection: 1) a medical record review of 485 nursing 

home residents taking psychotropic drugs; 2) an analysis of survey and certification and 

ombudsman program data; 3) an assessment of 135 nursing home Drug Regimen Reviews; 

4) on-site visits to 10 nursing homes; and 5) a telephone survey of 20 survey and 

certification and ombudsmen staff. We excluded anti-depressants from our review. 

FINDINGS 

Psychotropic drug use in nursing homes is generally appropriate 

Eighty-five percent of residents’ psychotropic drugs use is medically appropriate. Nearly 

all have the potential to benefit functionally from their drug therapy and are using the 

drugs within Medicare guidelines for appropriate use. 

Another 8 percent of residents are using psychotropic drugs inappropriately. These drugs 

are inappropriate for one or more of the following reasons: the dose is too high because 

Psychotropic Drug Use in Nursing Homes i OEI 02-00-00490 
appropriate dose reductions are not followed; there is unjustified chronic use of the drug; 

there is no documented benefit to the resident; the wrong type of drug is being given for a 

particular diagnosis; and there is unnecessary duplicate drug therapy. The use of 

psychotropic drugs as an inappropriate chemical restraint does not appear to be 

widespread; our medical record reviewers could not conclusively determine that any of the 

inappropriate drug use was a chemical restraint. Finally, for 7 percent of residents, 

reviewers could not determine the appropriateness of their psychotropic drug use due to 

insufficient medical record documentation. 

Data from survey and certification and ombudsman programs support the 

findings of the medical record review 

Deficiencies from the Online Survey Certification Reporting System that directly cite the 

misuse of chemical restraints and psychotropic drugs are not common. Deficiency tag 

F222, (inappropriate chemical restraints) comprises 0.08 percent of all deficiencies in the 

current survey and has decreased slightly over the past four surveys. Further, tag F329 

(unnecessary psychotropic drugs) comprises 2 percent of all deficiencies in the current 

survey and has remained constant. Also, most surveyors in our sample States concur that 

inappropriate chemical restraints are not common. 

Similarly, Ombudsman complaints specific to the inappropriate use of chemical restraints 

and psychotropic drugs are not prevalent. In 1999, complaints about physical and 

chemical restraints accounted for 1 percent of all nursing home complaints, while those 

about the use of psychoactive drugs comprised just 0.25 percent of the total. 

A growth in the proportion of nursing home residents with mental disorders may 

contribute to increasing psychotropic drug rates 

Data from the Online Survey Certification Reporting System show that from 1995 to 1999 

the overall national drug usage rate for anti-psychotics grew from 16 to 19.4 percent. 

During this time period, anti-anxiety drug rates increased from 14.3 to 15.7 percent. At 

the same time, data from this system show that over the last four surveys the proportion of 

residents with a documented psychiatric disorder, excluding dementia, increased from 13 

to 16 percent and the proportion with behavioral symptoms grew from 29 to 31 percent. 

Further, numerous articles have linked the increasing prevalence of mental disorders 

among nursing home residents to higher psychotropic drug rates. 

CONCLUSION 

In response to concerns expressed by the Senate Special Committee on Aging about the 

use of psychotropic drugs as inappropriate chemical restraints in nursing homes, this 

report finds that these drugs are generally being used appropriately. While drug usage 

Psychotropic Drug Use in Nursing Homes ii OEI 02-00-00490 
rates for anti-psychotic and anti-anxiety medications have been rising, most psychotropic 

drug use in nursing homes is medically appropriate. Where it is inappropriate, the 

problems do not appear to be related to inappropriate chemical restraints but rather to 

inappropriate dosage, chronic use, a lack of documented benefit to the resident, and 

inappropriate duplicate drug therapy. We do note, however, that lack of adequate 

documentation for residents’ psychotropic drug use is of some concern. The Centers for 

Medicare & Medicaid Services may consider educating providers to better document the 

appropriate use of these drugs. 

AGENCY COMMENTS 

We received comments on the draft report from the Centers for Medicare & Medicaid 

Services. They believe that the report will contribute to a better understanding of 

psychotropic drug use in nursing homes and in identifying areas for further focus. The 

CMS also notes that training related to psychotropic drug use and related documentation 

issues is already underway or planned. 

Psychotropic Drug Use in Nursing Homes iii OEI 02-00-00490 
TABLE OF CONTENTS 

PAGE

EXECUTIVE SUMMARY ................................................... i 

INTRODUCTION .......................................................... 1

FINDINGS

Nursing home psychotropic drug use generally appropriate ...................... 8

Survey and certification and ombudsman data support medical record review ........ 10

Growth in resident mental disorders may contribute to increasing drug rates ......... 11

CONCLUSION ........................................................... 14

APPENDIX

A: Confidence intervals for key medical record review findings .................. 15

B: Agency Comments ................................................ 16

Psychotropic Drug Use in Nursing Homes iv OEI 02-00-00490 
INTRODUCTION 

PURPOSE 

To assess the extent and nature of inappropriate psychotropic drug use in nursing homes 

and how it relates to chemical restraints. 

BACKGROUND 

The Senate Special Committee on Aging requested that the Office of Inspector General 

look at the extent to which psychotropic drugs in nursing homes are being used as 

inappropriate chemical restraints. Usage rates for these drugs have been increasing since 

1995. A chemical restraint is the use of a drug to control an individual’s behavior and is 

legally appropriate only if used to ensure the physical safety of residents or other 

individuals. 

We are also releasing a companion report entitled “Psychotropic Drug Use in Nursing 

Homes Supplental Information - 10 Case Studies,” OEI-02-00-00491, which presents 

information from on-site visits to ten nursing homes. 

Psychotropic Medications 

Psycho-pharmacologic medications are drugs that affect brain activities associated with 

mental processes and behavior. These drugs are also called “psychoactive” or 

“psychotherapeutic” medications. For clarity, we will refer to this class of drugs 

throughout our study as “psychotropics.” Psychotropic medications are divided into four 

broad categories: anti-psychotic; anti-depressant; anti-anxiety; and hypnotic medications. 

Anti-psychotic Drugs. Anti-psychotic medications are used to treat various psychoses 

and neurologic conditions. These include schizophrenia, schizoaffective disorder, 

delusional disorder, psychotic mood disorder, acute psychotic episode, Tourette’s 

syndrome, and Huntington’s disease. Other indications for long-term anti-psychotic use in 

the elderly are organic mental syndromes (including dementia with associated psychotic 

and/or agitated features defined by “certain behaviors” that are harmful to self or others) 

and mood disorders with psychotic features. 

Anti-psychotics are classified as either “conventional” or “atypical.” Conventional antipsychotics have several serious side effects. These side effects prompted the development 

of newer drugs called atypical anti-psychotics, which came onto the market 

Psychotropic Drug Use in Nursing Homes 1 OEI 02-00-00490 
in the mid 1990s. Clinical trials have demonstrated their effectiveness for a variety of 

disorders in the elderly, including schizophrenia and other psychoses. Although atypical 

anti-psychotics elicit fewer adverse reactions, other characteristics of these drugs, such as 

the effects on resident’s cognition, have not been thoroughly tested.1 

Anti-depressant Drugs. Anti-depressant drugs are usually used in the treatment of 

depression and agitation. Anti-depressants in low dosages are also used to treat insomnia. 

Side effects include excessive sedation, anti-cholinergic effects (dry mouth, constipation, 

urinary retention, blurred near vision, rapid heart rate, confusion, and disorientation), 

orthostatic hypotension (which can predispose a resident to falls), and electro 

cardiographic changes. Most anti-depressants have a long enough half-life that the 

elderly, who have lower tolerance levels for most drugs, require smaller and less frequent 

doses. 

Anti-anxiety and Hypnotic Drugs. Anti-anxiety drugs are used for the short-term 

management of anxiety and insomnia. Hypnotics are medications used for short-term 

sleep aids. However, even lower dosages of these two categories of drugs in the elderly 

population are associated with impairment of daytime functioning and may in some cases 

increase confusion and disorientation, which may in turn exacerbate problem behaviors.2 

Omnibus Budget Reconciliation Act of 1987 

On December 22, 1987, Congress enacted comprehensive nursing home reform with the 

Omnibus Budget Reconciliation Act (OBRA) of 1987 (P.L. 100-203). As part of OBRA 

1987, Congress passed the comprehensive Nursing Home Reform Act (NHRA). This Act 

mandates that residents be free from “physical or chemical restraints imposed for the 

purposes of discipline or convenience.” It also states that restraints may only be imposed 

to ensure the physical safety of the resident or other residents and only upon the written 

order of a physician that specifies the duration and circumstances under which the 

restraints are to be used. Further, NHRA limits the use of “as needed” (P.R.N.) orders 

and requires efforts to withdraw the drug or decrease dosage be made for residents who 

are receiving psychotropic drugs. 

Additionally, the Omnibus Budget Reconciliation Act (OBRA) of 1990 requires the 

regulation of certain drugs in nursing homes and the establishment of Drug Regimen 

Reviews for nursing home residents. The provisions of Section 4401 of OBRA 1990 

1 Cohen, Lawrence, J., Burke, William, J. (1999) “Appropriate Use of Anti-psychotics for 

Residents with Dementia in the Long-Term Care Setting,” Consultant Pharmacist 14, (2). 

2 Stimmel, Glen (1996) “Use of Sedation in Patients with Behavioral Disturbances of Dementia,” 

Consultant Pharmacist 11, (Supplement D): 9-11. 

Psychotropic Drug Use in Nursing Homes 2 OEI 02-00-00490 
involve pharmacists more actively in patient care by refocusing pharmacists from a 

product oriented role to one involving clinical practice responsibilities for reducing 

potential drug therapy problems. 

The Centers for Medicare and Medicaid Services Regulations 

To implement the requirements of OBRA 1987, on February 2, 1989, the Center for 

Medicare & Medicaid Services (CMS), formerly known as the Health Care Financing 

Administration, finalized regulations (42 C.F.R §483.25(1)) on anti-psychotic medications 

and unnecessary drugs. These regulations were further refined in 1991. The CMS 

regulations state that each resident’s drug regimen must be free from unnecessary drugs 

and define what is considered an unnecessary drug. An unnecessary drug is any drug 

used: 

C in excessive dose; 

C for excessive duration; 

C without adequate monitoring or without adequate indications for its use; 

C in the presence of adverse consequences, which indicate the dosage should

be reduced or discontinued; or 

C without specific target symptoms. 

In addition, the CMS regulations state that residents who have not previously used antipsychotic drugs should not be given these drugs unless anti-psychotic drug therapy is 

necessary to treat a specific condition as diagnosed and documented in the clinical record. 

Further, the regulation mandates that residents who use anti-psychotic drugs receive 

gradual dose reductions and behavioral interventions, unless clinically contraindicated, in 

an effort to discontinue these drugs. 

In July 1995, the CMS completed the final step in the implementation of OBRA 1987 by 

introducing new tasks into the nursing home survey process. Further refinements to 

survey procedures and interpretive guidelines were implemented on July 1, 1999. Some of 

these are specific to psychotropic drug therapy, including: new investigative protocols and 

the incorporation of quality indicators (QIs) based on the Minimum Data Set (MDS) into 

the off-site survey process; an update to the list of anti-psychotic drugs that can be cited 

as unnecessary or misused under tag number F329; the addition of drug therapy 

guidelines; and a revised definition of medication error. Additionally, the updated CMS 

regulations change some anti-psychotic dosing restrictions and list medications considered 

potentially hazardous to the elderly. 

Nursing Home Monitoring Programs 

Several programs exist to monitor the quality of care in nursing homes. These programs 

can act as a safeguard against the use of psychotropic drugs as inappropriate chemical 

Psychotropic Drug Use in Nursing Homes 3 OEI 02-00-00490 
restraints and provide a venue for receiving and handling complaints about such misuse. 

Nursing Home Survey and Certification. All Medicare and/or Medicaid participating 

nursing homes must be certified in meeting certain Federal requirements. Nursing home 

certification is achieved through routine surveys. The CMS contracts with States to 

perform these surveys for Medicare and dually-eligible nursing homes. All nursing homes 

are subject to an unannounced standard survey “no later than 15 months after the date of 

the previous standard survey.” If during the standard survey a nursing home is found to 

have provided substandard quality of care, an additional extended survey will be 

conducted within 2 weeks. During either type of survey, a surveyor may cite the nursing 

home for a deficiency if that facility fails to meet specific requirements. 

Survey deficiencies are categorized, collected, and reported in the Online Survey 

Certification and Reporting System (OSCAR). Several deficiencies relate directly to 

pyschotropic drug misuse. For example, tag number F329 is cited for all unnecessary 

drugs including: anti-anxiety, anti-depressant, anti-psychotic, and hypnotic drug use. Tag 

number F330 is specific to anti-psychotic drug use in residents who do not have a specific 

condition as diagnosed and documented in the medical record, and tag number F222 is 

cited for inappropriate chemical restraints. In addition, other tags that address quality of 

care, resident’s rights, and drug regimen reviews also indirectly relate to the misuse of 

psychotropic drugs. 

Ombudsman Program. The State Long Term Care Ombudsman program was 

established in 1978 by the Older Americans Act to ensure quality of care and advocacy on 

behalf of long term care residents. It requires that each State have an Ombudsman 

program, which are run by States and local communities and use both paid and volunteer 

staff. The programs have multiple functions including: identifying, investigating, and 

resolving complaints made on behalf of residents; protecting the legal rights of residents; 

and providing information and consultation to residents and families. 

All of the States systematically collect and report data relating to their Ombudsman 

Program under the National Ombudsman Reporting System (NORS). Two of the 

complaint categories in NORS specifically relate to the use of psychotropic drugs - one for 

chemical and physical restraints and the other for psychotropic drug assessment, use, and 

evaluation. Other categories indirectly address this problem, such as weight loss, 

assistance in eating, and functionality. 

METHODOLOGY 

We combined five methods for this inspection: 1) a medical record review of residents 

taking psychotropic drugs; 2) an analysis of nursing home survey and certification and 

Psychotropic Drug Use in Nursing Homes 4 OEI 02-00-00490 
ombudsman program data; 3) an assessment of nursing home Drug Regimen Reviews; 4) 

on-site visits to 10 nursing homes; and 5) a telephone survey of State survey and 

certification and ombudsmen staff. The findings of the on-site visits are presented in a 

companion report, “Psychotropic Drug Use in Nursing Homes Supplemental Information -

10 Case Studies,” OEI-02-00-00491. 

We excluded anti-depressants from our review because depression in nursing home 

residents has historically been under-diagnosed and under-treated. Therefore, the increase 

in anti-depressant use is generally considered to be appropriate. 

Nursing home and resident sample 

We used a two-stage cluster sample for this inspection. In the first stage of sampling, we 

used the OSCAR current survey file to select a random sample of 203 nursing homes. 

For each of the nursing homes in our sample, we requested their enrollment census for the 

month of November 2000. From this census, we asked the nursing homes to identify 

which residents received a psychotropic drug and what type (anti-psychotic, anti-anxiety, 

hypnotics, and/or anti-depressants) they received. We obtained a response from 196 of 

the 203 nursing homes, for an overall response rate of 97 percent. 

In the second stage of sampling, we selected a random sample of 587 nursing home 

residents. From each of the 196 nursing home enrollment lists we randomly selected 3 

residents who received either an anti-psychotic, anti-anxiety, and/or a hypnotic during 

November 2000 (we excluded residents solely on anti-depressants). One nursing home 

had only two residents who met these criteria and we sampled both residents. 

Medical record review 

For each of the residents in our sample, we requested their complete clinical records for 

May 2000 through November 2000. Among the documentation we requested were 

admission sheets, plans of care, nurses’ and physicians’ notes, medication administration 

records, psychiatric and neurological assessments, behavior management records, and 

physician orders. 

We received 574 of the 587 medical records that we requested, for a medical record 

response rate of 98 percent. If we had obtained a response from all 203 nursing homes in 

our first stage of sampling and had sampled 3 residents from each one, our overall 

response rate for medical records would have been 94 percent. Of the 574 medical 

records we did receive, we sent 485 for medical record review. The other 89 residents did 

not meet our sampling criteria and were excluded from the medical record review. While 

they were identified by their nursing home as having received a psychotropic drug in 

November 2000, their record showed no evidence that they had actually used the drug. 

Many of these residents had PRN (“as necessary”) orders that were not administered in 

November. Other residents were taking these drugs for non-psychiatric reasons. 

Psychotropic Drug Use in Nursing Homes 5 OEI 02-00-00490 
We used an independent contractor to conduct the medical record review. First, together 

with the contractor, we developed a screening instrument to review the residents’ records. 

The screening instrument was based on the CMS guidelines for the appropriate use of 

psychotropic drugs. We also obtained input on this instrument from the American 

Association of Geriatric Psychiatrists and the American Medical Directors Association. 

Nurse screeners with geriatric experience initially reviewed all the records; the cases that 

did not pass this initial screening were passed on for second level review. 

Both a geriatric psychiatrist and a consultant pharmacist conducted the second level 

review. These reviewers determined a drug to be inappropriate if, based on the clinical 

documentation in the medical record, the drug was not medically necessary or reasonable. 

See Appendix A for confidence intervals on key findings of the medical record review. 

Analysis of nursing home survey and certification and ombudsman program data 

We examined data from both the OSCAR and NORS. In OSCAR, we looked at nursing 

home deficiencies for chemical restraints (F222), unnecessary psychotropic drugs (F329), 

and psychotropic drug use in the absence of a documented diagnosis (F330). In NORS, 

we looked at complaints made to Ombudsman about physical and chemical restraints 

(H60) and psychoactive drugs (H62). For both sets of data, we looked at both the 

prevalence of and changes over time for each of the specific deficiencies and complaints. 

Assessment of Drug Regimen Reviews 

From the 196 nursing homes that responded to our request for an enrollment list, we 

requested 6 months of drug regimen reviews (DRRs). Overall, 135 nursing homes 

submitted these DRRs. We did not follow-up with the other 61 nursing homes. We 

reviewed a selection of these DRRs to determine how they assure that psychotropic drugs 

are being used appropriately. 

Site visits 

We selected a purposive sub-sample of 10 nursing homes in different States to visit onsite. These 10 nursing homes were selected based on five criteria: 1) geographical 

location, 2) number of residents in November 2000, 3) drug usage rate, 4) urban/rural 

location, and 5) ownership status. We chose nursing homes in California, Florida, Idaho, 

Maryland, Massachusetts, Missouri, New York, Ohio, Texas, and Wisconsin. Five of the 

facilities were large (more than 100 residents), four were medium (61-99 residents), and 

one was small (less than 60 residents). Also, four of the homes had a high psychotropic 

drug usage rate (greater than 34 percent), four had a moderate rate (18 to 34 percent), 

and two had rates of less than 18 percent. Lastly, eight of the nursing homes were located 

in an urban area while two were rural, and nine were for-profit while one was non-profit. 

While on-site at these 10 facilities, we interviewed both administrative as well as direct 

care staff. Our administrative interviews included discussions with nursing home 

Psychotropic Drug Use in Nursing Homes 6 OEI 02-00-00490 
administrators, directors of nursing, medical directors, consultant pharmacists, 

psychiatrists, social workers, and psychologists. We spoke with these respondents about 

how psychotropic drugs are being used and monitored in their facility. 

We also interviewed nurses and certified nurse aides in each facility separately from 

administrative staff about how they care for and monitor residents on psychotropic drugs 

and handle aggressive residents. Lastly, while on-site we spoke with and observed the 

residents in our sample and toured the facility, including observing at least one structured 

activity and meal time. 

Telephone interviews with State surveyors and ombudsmen 

For the States represented in our purposive sub-sample, we conducted two structured 

telephone interviews - one with the State ombudsman and the other with the State survey 

and certification director or other manager. During these interviews, we discussed with 

respondents how pyschotropic drugs are being used by nursing homes in their State, the 

nature and extent of inappropriate chemical restraints, and the processes that their State 

has in place to handle such complaints. 

Limitations 

Our methodology has two main limitations. First, we assessed the appropriateness of 

psychotropic drugs based solely on a medical record review and not on in-person clinical 

assessments of the residents in our sample. For example, our reviewers state that they 

could not conclusively determine if any inappropriate drug use was an inappropriate 

chemical restraint without a physical examination of the resident. Second, the nursing 

homes in our sample self-identified the residents that were receiving psychotropic drugs in 

November 2000. 

This inspection was conducted in accordance with the Quality Standards for 

Inspections issued by the President’s Council on Integrity and Efficiency. 

Psychotropic Drug Use in Nursing Homes 7 OEI 02-00-00490 
FINDINGS 

Psychotropic drug use in nursing homes is generally appropriate 

Our medical record review shows that 85 percent of nursing home residents who take 

psychotropic drugs are taking drugs that are medically appropriate. Another eight percent 

are using psychotropic drugs inappropriately, and for seven percent our reviewers could 

not determine the appropriateness of their psychotropic drug therapy due to insufficient 

medical record documentation. See Graph 1 below. 

Graph 1 

Nursing Home Residents’ Psychotropic Drug Use 

Source: Medical Record Screening Instrument, 2001 

Eighty-five percent of residents’ psychotropic drug use is medically appropriate 

Most nursing home residents taking psychotropic drugs are taking drugs that are medically 

appropriate. Nearly all of these residents have the potential to benefit functionally from 

their drug therapy and there is evidence that, for most, their therapeutic goal has been or 

can be achieved. Also, in accordance with the CMS guidelines, in most cases the 

psychotropic drugs are being used at appropriate dosages and duration and not as 

inappropriate duplicate therapy. The drugs are also generally being used with adequate 

indications and monitoring and without adverse consequences. 

Psychotropic Drug Use in Nursing Homes 8 OEI 02-00-00490 
Nearly all residents taking anti-psychotic drugs (95 percent) or anti-anxiety drugs (93 

percent) have a documented diagnosis of mental illness. More specifically, among 

residents on anti-psychotic drugs, the most common diagnosis is dementia with associated 

psychotic or agitated behaviors (71 percent), while 14 percent have a diagnosis of 

schizophrenia. Close to half of residents taking anti-anxiety drugs (43 percent) have a 

diagnosis of dementia of the Alzheimer’s type with behavioral disturbance. For the few 

residents with no documented mental health diagnosis, most are appropriately taking an 

anti-psychotic or anti-anxiety drug due to an acute problematic behavior. 

We noted several features of nursing homes’ Drug Regimen Reviews (DRRs) that may 

help to assure that psychotropic drugs are used appropriately. These DRRs are conducted 

on a monthly basis by pharmacists to assess residents’ drug treatment plans. Many of the 

DRRs we reviewed include the pharmacist’s recommendation to change a medication in 

order to improve the management of a resident’s behavioral symptoms, as well as a 

recommendation to re-evaluate or discontinue PRN (“when necessary”) drug orders. The 

DRRs also commonly include a suggestion to decrease dosage, a reminder that reduction 

attempts are past due, or an identification of medication errors, such as when 

inappropriate duplicate drugs are being given. In many cases, the resident’s physician 

concurs with the pharmacist’s recommendation and indicates this agreement on the DRR. 

Eight percent of residents are using psychotropic drugs inappropriately 

Eight percent of residents who take psychotropic drugs are using these drugs 

inappropriately. These drugs are inappropriate for one or more of the following reasons: 

the dose is too high because appropriate dose reductions are not followed; there is 

unjustified chronic use of the drug; there is no documented benefit to the resident; the 

wrong type of drug is being given for a particular diagnosis; and there is inappropriate 

duplicate drug therapy. For example, in a few cases an additional anti-psychotic drug is 

being given to treat symptoms without dose adjusting on the first drug to a level that 

would effectively treat the resident. In many instances there is no clear documentation to 

support continued need for duplicate or triplicate drug therapy. Residents on more than 

one psychotropic drug are more likely than residents on just one psychotropic drug to be 

taking a medication inappropriately. 

There do not appear to be any nursing home characteristics associated with inappropriate 

use. Neither ownership type nor urban or rural setting are linked with inappropriate use of 

these drugs. Also, nursing homes with higher psychotropic drug usage rates are not more 

likely than homes with medium and low rates to inappropriately use these drugs. 

However, nearly all nursing home surveyors and some ombudsmen we interviewed say 

that inadequate nursing home staffing ratios, training, and experience may be associated 

with a greater likelihood of inappropriate drug use. 

Inappropriate chemical restraints do not appear to be widespread. Our medical record 

reviewers could not conclusively determine that any of the inappropriate drug use was an 

inappropriate chemical restraint. In follow-up discussions with reviewers, all agree that 

Psychotropic Drug Use in Nursing Homes 9 OEI 02-00-00490 
based on their medical record review, the use of psychotropic drugs as inappropriate 

chemical restraints, solely for the convenience of staff, does not appear to be common. 

Seven percent of residents’ medical records lack sufficient documentation to 

determine the appropriateness of their psychotropic drug use 

Seven percent of residents we sampled have such inadequate records that our medical 

record reviewers are unable to determine if their drug use is appropriate. Some of these 

residents’ records lack information about their mental health history, while others’ lack 

physician notes on the medical rationale for why the drug is being used. For example, 

several residents were taking hypnotic drugs without any note of sleeping problems in 

their records. However, based on their clinical judgement and other documentation in the 

record, our reviewers believed that these drugs may have been appropriate. 

There are two other ways in which nursing home documentation for these drugs is 

insufficient. Of the records that went for second level review, there was not always 

adequate documentation to explain why residents were taking psychotropic drugs outside 

of the CMS dosage guidelines (even though the medical reviewers determined that the 

dosage was appropriate). Also, some records do not have adequate documentation to 

support the duration of time the resident has been receiving the drug. In fact, our medical 

reviewers cite this as one of the biggest documentation problems. They state that 

documentation to justify the appropriateness of chronic use of pyschotropic drugs is often 

lacking since residents’ records commonly lack physician notes to support ongoing drug 

therapy. 

Data from survey and certification and ombudsman programs support 

the findings of the medical record review 

The OSCAR deficiencies that directly cite inappropriate psychotropic drugs and chemical 

restraints are not common. Deficiency tag F222, cited for inappropriate chemical 

restraints, comprises 0.08 percent of all deficiencies in the current survey, and the number 

of these deficiencies has been decreasing slightly over the past three surveys. Further, tag 

F329, cited for unnecessary psychotropic drugs, comprises 2 percent of all deficiencies in 

the current survey; the number of these deficiencies has remained constant. Lastly, tag 

F330, cited for the use of a psychotropic drug in the absence of a documented diagnosis, 

accounts for 0.13 percent of all deficiencies; these deficiencies have also seen a small 

decrease. It should be noted that other deficiencies, such as pressure sores and weight 

loss, may indicate that psychotropic drugs are being used as inappropriate chemical 

restraints. 

Similarly, ombudsman complaints specific to the inappropriate use of psychotropic drugs 

and chemical restraints are not prevalent. In 1999, complaints about physical and chemical 

restraints accounted for 1 percent of all nursing home complaints, while those about the 

use of psychoactive drugs comprised just 0.25 percent of the total. 

Psychotropic Drug Use in Nursing Homes 10 OEI 02-00-00490 
Furthermore, the number of these complaints, while increasing slightly from 1996 to 1998, 

have decreased from 1998 to 1999. 

Also, most surveyors and some ombudsmen in our sample States concur that 

inappropriate chemical restraints are not common. Most of the 10 surveyors we 

interviewed say that use of psychotropic drugs as inappropriate chemical restraints is 

uncommon. While fewer ombudsmen agree, most say that only a small number of nursing 

homes are using the drugs inappropriately. Further, a majority of both surveyors and 

ombudsmen in our sample report that over the past three years, the inappropriate use of 

these drugs as inappropriate chemical restraints has decreased or remained the same. 

Several respondents in our sample States say that chronic drug use may be more of a 

problem. One surveyor says: “The decision to use the drug might be right but [nursing 

homes] might not handle it correctly as [they] go along.” An ombudsman agrees: “[It] 

may have been appropriate to use the drug at the start, but not keep the resident on the 

drug for 5 years.” 

A growth in the proportion of nursing home residents with mental 

disorders may contribute to increasing psychotropic drug rates 

More residents are taking psychotropic drugs 

Since 1995, nursing home psychotropic drug usage rates have increased. This increase 

occurred after initial drops in usage rates following the implementation of OBRA 87. The 

largest increase has occurred with the use of anti-psychotics. Based on OSCAR data, 

from 1995 to 1999 the national rate for anti-psychotics grew from 16 percent to 19.4 

percent, and anti-anxiety drug rates increased from 14.3 percent to 15.7 percent.3 

However, hypnotic drug rates have remained relatively steady at 5 percent for this time 

period. 

Based on our sample, which excluded residents taking only anti-depressants, antipsychotics appear to be the most prevalent of the different groups of psychotropic drugs. 

Sixty-seven percent of residents on psychotropic drugs are taking an anti-psychotic 

medication, while 42 percent are taking an anti-anxiety drug, and far fewer (17 percent) 

are taking a hypnotic medication. Overall, more than half of these residents are taking two 

or more psychotropic drugs. 

Nursing homes have a higher proportion of residents with mental disorders 

The population of residents with mental disorders in nursing homes has also been growing. 

Data from OSCAR show that the proportion of all residents with a documented 

3

 American Society of Consultant Pharmacists Fact Sheet, September (2000). 

Psychotropic Drug Use in Nursing Homes 11 OEI 02-00-00490 
psychiatric disorder, excluding dementia, increased from 13 percent to 16 percent over the 

last four surveys. Also, the proportion of all residents with behavioral symptoms grew 

from 29 percent to 31 percent over the same period. Further, in our telephone interviews 

two ombudsmen say they are seeing more problem behavior and dementia among nursing 

home residents in their States. Lastly, one of our medical record reviewers, a geriatric 

psychiatrist, mentions that nursing homes are different now than they were when OBRA 

87 was first implemented, due to the higher proportion of psychiatric residents. 

Numerous articles have also documented the increasing prevalence of mental disorders 

among nursing home residents. In one article examining the effects of OBRA 87 on 

psychotropic prescribing rates, the authors argue that “the prevalence of psychiatric 

disorders in long-term care facilities is formidable, and nursing homes have become 

defacto mental health facilities.”4 When discussing the impact this has had on 

psychotropic drug use, they caution against “trends that equate low utilization ... with 

high-quality care, without considering other factors such as improvements in the quality of 

life associated with appropriate use of psychotropic medications.”5 In another article from 

the Consultant Pharmacist, the authors state that “the small but meaningful increase in 

usage seen in several categories ... may be explained by an increase in [behavioral] acuity 

of patients.”6 

Lastly, nursing homes appear to be accepting more residents with a history of 

psychotropic drug use. At least one third of the residents in our sample entered the 

nursing home already on their medication. Several of our medical record reviewers point 

out that hospitals’ common use of these drugs results in new nursing home admissions 

who already have a prior history of taking psychotropic medications. Finally, a few of the 

administrators at the nursing homes we visited say that they try to reduce drug levels for 

residents entering the home already taking high dosages. 

Four of the 10 nursing homes we visited are actively seeking out psychiatric 

patients 

Four of the 10 nursing homes we visited specifically target psychiatric patients. All four 

have psychotropic drug usage rates that are above the national average. These nursing 

homes actively seek out such patients because they have developed the expertise and 

staffing structure necessary to care for residents with a mental illness. Some 

4

 Lantz, Melinda, Giambanco, Vincent, and Buchalter, Eric. (1996) “A Ten-Year Review of the 

Effect of OBRA-87 on Psychotropic Prescribing Practices in an Academic Nursing Home,” Psychiatric 

Services. 

5 Lantz, (1996). 

6

 Tobias, Dianne and Pulliam, Charles. (1997) “General and Psychotherapeutic Medication Use in 

878 Nursing Facilities: A 1997 National Survey,” Consultant Pharmacist. 

Psychotropic Drug Use in Nursing Homes 12 OEI 02-00-00490 
administrators mention that in order to remain financially viable, they need to target this 

segment of the nursing home population; residents with lesser care needs or with less 

advanced dementia or Alzheimer’s disease are increasingly going to other long term care 

settings, such as assisted living centers. 

Psychotropic Drug Use in Nursing Homes 13 OEI 02-00-00490 
CONCLUSION 

In response to concerns expressed by the Senate Special Committee on Aging about the 

use of psychotropic drugs as inappropriate chemical restraints in nursing homes, this 

report finds that these drugs are generally being used appropriately. While drug usage 

rates for anti-psychotic and anti-anxiety medications have been rising, most psychotropic 

drug use in nursing homes is medically appropriate. Where it is inappropriate, the 

problems do not appear to be related to inappropriate chemical restraints but rather to 

inappropriate dosage, chronic use, a lack of documented benefit to the resident, and 

inappropriate duplicate drug therapy. We do note, however, that lack of adequate 

documentation for residents’ psychotropic drug use is of some concern. The Centers for 

Medicare and Medicaid Services may consider educating providers to better document the 

appropriate use of these drugs. 

AGENCY COMMENTS 

We received comments on the draft report from the Centers for Medicare & Medicaid 

Services. They believe that the report will contribute to a better understanding of 

psychotropic drug use in nursing homes and in identifying areas for further focus. The 

CMS also notes that training related to psychotropic drug use and related documentation 

issues is already underway or planned. 

Psychotropic Drug Use in Nursing Homes 14 OEI 02-00-00490 
APPENDIX A 

Confidence Intervals for Key Medical Record Review Findings 

We calculated confidence intervals for the medical record review key findings. The point 

estimate and 95% confidence intervals are given for each of the following: 

KEY FINDINGS POINT 

ESTIMATE* 

CONFIDENCE 

INTERVAL 

Nursing home residents who are taking 

psychotropic drugs that are medically 

appropriate 85 % 81 % - 89% 

Nursing home residents who are taking 

psychotropic drugs that are medically 

inappropriate 8% 5 % - 11% 

Nursing home residents whose medical records 

lack sufficient documentation to determine the 

appropriateness of their psychotropic drug use 7 % 4 % - 10 % 

* N = 485 

Psychotropic Drug Use in Nursing Homes 15 OEI 02-00-00490 
APPENDIX B 

Comments on the Draft Report 

In this appendix, we present in full the comments from the Centers for Medicare & 

Medicaid Services. 

Psychotropic Drug Use in Nursing Homes 16 OEI 02-00-00490 
Psychotropic Drug Use in Nursing Homes 17 OEI 02-00-00490 
Psychotropic Drug Use in Nursing Homes 18 OEI 02-00-00490