Society Submits Comments on Participation Requirements for LTC Facilities

September 19, 2019
Policy Snapshot

Last week the Society submitted comments to the Centers for Medicare & Medicaid Services (CMS) on the Requirements for Long-Term Care Facilities Proposed Rule. Overall, the Society supported the proposed regulatory updates, as many reflect the work being done with CMS.

CMS’ proposed rule included revisions to guidance regarding use of PRN antipsychotic medications. The Society noted that it supported these changes, which would treat PRN orders for antipsychotic medications the same as for other psychotropic medications. The current requirement limits the use to 14 days and mandates a face-to-face visit before reordering. The Society felt that it is not consistent with current medical standards of care, imposes unnecessary burden on both patients as well as prescribers, increases the risk of shifting antipsychotic orders from PRN to standing, and potentially delays appropriate treatment to patients. The Society also offered guidance related to safe prescribing and joined the American Society of Consultant Pharmacists and other organizations in showing support for the change and “believe these changes will improve care by enabling health care professionals to better use their time attending to the needs of residents rather than on administrative tasks.”

The Society also commented on other changes, noting no objections to the new guidance for infection preventionists being changed from “part-time” to “sufficient time.” The Society did note the potential for confusion with the new terms and noted that, “regardless of the term selected, the time devoted to the duties of the infection preventionist should be based on the facility risk assessment, the number and types of residents cared for, baseline incidence rates of endemic infections, seasonal variations in incidence of certain infections (e.g. influenza and norovirus), the presence of outbreaks, and programmatic efforts aimed at antimicrobial stewardship programs. As such, the time devoted will not only vary from facility to facility but will also vary within a facility over the course of the year.”

The Society further noted support for a proposed revision to the Quality Assurance and Performance Improvement Program (QAPI) that will allow facilities the flexibility to mold their QAPI programs to best fit their individual residents' needs and to ensure the program is meaningful for each facility. Also supported were the changes to remove the requirements to notify the ombudsman whenever a patient is being transferred to an acute care facility.

Click here to read the full comments.