Blog Post by Mark Prifogle, CEO GrandView Pharmacy

CMS recently shared that they are making a few More technical changes to the interpretive guidance before issuing a final version of Appendix PP. We anticipate CMS will release a final version of Appendix PP by or around November 28, 2017. In addition, CMS has made some of the related changes to the critical element pathways and posted the updates with a date of November 8 on their website here. Below is a summary of the changes CMS has told us they have made or will be making to the guidance and pathways. Note that several other pathways in the zipped file at the link above appear to also have a new date of 11-8-17, and we are seeking additional information about any further changes to those pathways.

Administering Crushed Oral Medications

  • AHCA, along with ASCP and other stakeholders, provided feedback to CMS regarding the guidelines for crushing and combining oral medications into food. In response to those concerns, CMS is revising the interpretive guidance to convey that best practice would be to separately crush and administer each medication with food to address concerns with physical and chemical incompatibility of crushed medications and ensure complete dosaging of each medication. However, they will add new guidance that separating crushed medications may not be appropriate for all residents and should not be counted as a medication error unless there are instructions not to crush the medication(s). Facilities should use a person-centered, individualized approach to administering all medications. If a surveyor identifies concerns related to crushing and combining oral medications, the surveyor should evaluate whether facility staff have worked with the resident/representative and appropriate clinicians (e.g., the consultant pharmacist, attending physician, medical director) to determine the most appropriate method for administering medications which considers each resident’s safety, needs, medication schedule, preferences, and functional ability. Interpretive guidance related to crushed medications administered via feeding tube will remain unchanged.
  • CMS has revised the facility task/pathway for Medication Administration Observation, CMS 20056, to reflect this change.