There are no specific survey guidelines for evaluating a facility that triggers this quality indicator. The guidelines given to surveyors to evaluate drug therapy are found in the interpretive guidelines at tag F329 and tag F429. These guidelines apply to all residents in the facility, not just those taking nine or more medications. The interpretive guidelines are designed to evaluate the use of specific individual medications and do not provide guidance to surveyors in evaluating the appropriateness of a complex multidrug regimen. In fact, a high level of clinical expertise and knowledge of pharmacology and practice guidelines is required to evaluate appropriateness of such a drug regimen.
Few surveyors have such expertise.
In many states, no pharmacist or physician even serves as a surveyor for nursing facilities. In conclusion, ASCP shares HCFA's desire that all nursing facility residents receive appropriate drug therapy and we are willing to work with HCFA to develop additional drug therapy indicators for use in the survey process. ASCP believes that the quality indicator on the use of nine or more medications is having a net negative impact on the quality of care provided to nursing facility residents. The Health Care Financing Administration should discontinue the use of this indicator as soon as possible. Each nursing facility resident should receive the drug therapy that is needed and appropriate for that resident.