F758 is and will continue to be one of the most frequently cited CMS Ftags. This Ftag involves the use of unnecesary psychotropic medications. F758 used to be under one general umbrella of F329 in the previous Ftags. I broke down Ftag 757 in one of my previous blog posts. There really isn’t much difference here, with the exception that F758 will only be cited for psychotropic medications while F757 can be cited for any other medication.
The difference in the numbering of the F-Tags doesn’t really matter much, but what is extremely important is to recognize any changes in the regulations. There is one major change that you have to be aware of. As needed medications for anxiety, sleep, or other psych condition CANNOT be used for more than 14 days. If they are used for more than 14 days, you must have documentation to justify its prolonged used. I do understand why this was added to the F758 category. Often in my practice as a consultant pharmacist, these as needed orders would linger for months, maybe even years and seldom be used. In my mind, this regulation is to ensure that patients are reassessed by a medical provider prior to using these medications.
Let’s take an example scenario as to why this regulation does have some meaning. JS is a 76 year old female with dementia. She has had significant anxiety and was prescribed lorazepam 0.5 mg twice daily as needed. She was prescribed this a few days after a fall (probably inappropriately) when her pain and anxiety were the worst. The order was continued and 3 months later, she has increasing anxiety and confusion. The nurse who is newer to the facility begins to give her the medication every night for the anxiety. This exacerbates the confusion. Days after the symptoms first started, she was assessed by the attending physician. She was diagnosed with a urinary tract infection as she was displaying some flank pain. The lorazepam was not necessary and was used to manage a different situation. If nursing staff did not have this available, there would have likely been an assessment sooner.
The 14 days for PRN use is the major change here that you may need to alter your policies and procedures because of this. Many facilities I have worked at have been very good about limiting the amount of available PRN’s. I do think minimizing PRN’s where possible is a good strategy to prevent unnecessary medication use (not to mention reduce risk for drug diversion possibilities for controlled substances like benzodiazepines).
Other than the 14 day requirement, facilities being cited for F758 will be for the usual reasons. Not attempting a gradual dose reduction, poor documentation of rationale for ongoing use, and inadequate monitoring of target behaviors for use are the most common culprits for deficiency.
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