ASCP does not support the overly restrictive prior consent provisions of the final rule because the daily activities performed by consultant pharmacists in reviewing patient medication regimens will be negatively impacted by such a burdensome provision. DRR is an overall evaluation and review of the medications used. These recommendations, which must be addressed by the medical director and director of nursing in the facility, often result in discontinuation of medication therapy or addition of medication therapy when appropriate. DRR also identifies actual and potential adverse drug reactions. This process requires the pharmacist to examine the entire medical record to make informed recommendations and report irregularities to the medical director and the director of nursing.
Pharmacists often review many patient medical records per day.
To require prior consent is overburdensome and would decrease the amount of time the pharmacist spends reviewing the medical records. Below is an example of a situation that will result in negative consequences for nursing facility residents if consultant pharmacists are burdened by the overly restrictive prior consent requirement. This is especially true considering the medication review process begins in the pharmacy upon receipt of a prescription order from a prescriber before a resident is admitted to a long-term care facility. In addition to problems related to DRR, the prior consent requirement presents difficulties in the prescription dispensing process. This stringent provision would interrupt systems proven to improve the medication distribution process already in place to allow pharmacists to fill a prescription order upon receipt.