Failure to Document Physician Response to Pharmacist Medication Regimen Review
Summary
The facility failed to ensure that the attending physician documented review of the consultant pharmacist’s monthly medication regimen review (MRR) recommendations and actions taken in response for one resident reviewed for unnecessary medications. Review of the resident’s MRR notes from April 2025 through April 2026 showed the pharmacist documented completion of the MRRs and noted on 07/09/25 that a recommendation regarding fluid restriction was being sent. When surveyors requested the July 2025 MRR containing the specific fluid restriction recommendation and the physician’s response, the facility was unable to provide this document for review. The DON in training confirmed the July 2025 MRR for this resident could not be located. Further review of the December 2025 MRR for the same resident revealed the consultant pharmacist recommended a gradual dose reduction trial for Abilify, Trazodone, and Vilazodone. There was no documentation that the attending physician reviewed this MRR or responded to the pharmacist’s recommendations, and the January 2026 MRR showed the pharmacist repeated the same recommendation. The DON in training confirmed there was no documentation that the attending physician addressed the pharmacist’s December 2025 recommendations. This was inconsistent with the facility’s Medication Regimen Review policy, which states that pharmacist-reported irregularities are to be reviewed and a response provided in a timely manner, and that pharmacist recommendations are considered part of the medical record.
Penalty
Resources
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A resident with Parkinson’s disease, dementia, and hypothyroidism was prescribed levothyroxine once daily along with other medications. A consultant pharmacist’s monthly drug regimen review recommended that levothyroxine be given in the morning on an empty stomach, 30–60 minutes before food, per manufacturer instructions. The medical record contained no documented physician response to this recommendation, and the MAR showed the drug scheduled for morning administration while the resident was observed eating breakfast and receiving the medication at the same time. An LPN confirmed administering levothyroxine during the meal, and the DON verified there was no documentation explaining whether or why the pharmacist’s recommendation was or was not followed, resulting in a failure to act on and document the identified irregularity.
The facility failed to act on consultant pharmacist drug regimen review (MMR) recommendations within its required timeframe for two cognitively intact residents receiving psychotropic medications. For one resident with multiple psychiatric and neurologic diagnoses, GDR recommendations for trazodone and amitriptyline were not reviewed and responded to until well beyond a month after the pharmacist’s notes. For another resident with extensive cardiopulmonary, metabolic, and psychiatric comorbidities, a recommended GDR of sertraline was not addressed by the provider until several weeks after issuance. The DON and Administrator acknowledged that these pharmacy recommendations were not handled in a timely manner, despite facility policy requiring action on identified irregularities and recommendations no later than 30 days.
A resident with multiple comorbidities, including DM, CKD, morbid obesity, and mobility impairment, had a PRN order for Hydroxyzine Pamoate 25 mg. The consulting pharmacy later recommended discontinuation of this drug, and the physician signed to discontinue it, but nursing staff continued to administer the medication and the order remained active on the MAR for several weeks afterward. This resulted in the resident receiving doses of Hydroxyzine despite the documented decision to stop the medication, contrary to facility policy requiring medications to be administered in accordance with prescriber orders.
The facility did not ensure timely and appropriate action on pharmacist drug regimen reviews for two residents. For one resident with multiple comorbidities receiving doxycycline, magnesium oxide, and ferrous sulfate, the pharmacist and physician agreed to separate administration times to improve absorption, but nursing staff did not change the MAR administration time for magnesium oxide as ordered. For another cognitively intact resident with DM, mental health diagnoses, paraplegia, and breast cancer, pharmacy recommendations for a gradual dose reduction of amitriptyline and clarification of two PRN lorazepam orders received limited physician responses and no further documented follow-up, despite facility policy requiring timely review, documentation of actions or rationale, and transcription of new orders.
Failure to Follow Up on Pharmacy Recommendations: A resident with multiple chronic conditions, including dementia, depression, and hypertensive heart disease, had several pharmacy review recommendations that were not responded to or documented as followed up by the facility. The recommendations involved clarification of Norvasc after hospital discharge, review of Hydroxyzine HCL PRN use without a stop date, and consideration of increasing Donepezil dosing per manufacturer guidance; the DON confirmed the recommendations were not addressed.
Delayed review of pharmacy recommendations and incomplete medication monitoring affected three residents. One resident with COPD, AFIB, malnutrition, and weight loss had a medication change delayed and later pharmacy requests left unaddressed; another resident with diabetes, COPD, and psychiatric diagnoses continued receiving budesonide despite a pharmacy question about ongoing need; and a third resident with schizophrenia, dementia, and multiple chronic conditions had delayed physician review of the MRR, an unacted-upon pharmacy recommendation, and AIMS assessments for Geodon that were not completed every 6 months.
Failure to Act on Pharmacist Drug Regimen Recommendation for Thyroid Medication
Penalty
Summary
The deficiency involves the facility’s failure to ensure that pharmacy recommendations from the monthly drug regimen review were acted upon and documented for a resident. The resident was admitted with diagnoses including Parkinson’s disease, dementia, and hypothyroidism, and had current physician orders for levothyroxine 150 mcg once daily, buspirone 50 mg twice daily, and losartan 100 mg once daily. A medication regimen review dated 11/25/2025 included a consultant pharmacist recommendation that levothyroxine be administered consistently in the morning on an empty stomach, at least 30–60 minutes before food, per manufacturer instructions. There was no specific physician response in the medical record to this recommendation, and the facility’s policy stated that consulting pharmacist reviews are sent to nursing and addressed with the primary care provider or consulting specialist for review and follow-up. Review of the resident’s medication administration record for April 2026 showed levothyroxine scheduled for 9:00 a.m. On observation, the resident was seen eating breakfast in the dining area at 8:03 a.m., and an LPN reported administering the levothyroxine 150 mcg to the resident while the resident was in the dining area eating breakfast. The DON confirmed there was no evidence in the resident’s medical record explaining why the consultant pharmacist’s recommendation from 11/25/2025 was or was not acted upon. This lack of documented physician review and action on the pharmacist’s identified irregularity constituted noncompliance with the drug regimen review requirements.
Plan Of Correction
F756 The facility will continue to ensure the pharmacy recommendations from the monthly drug regimen review by a licensed pharmacist are acted upon for all residents, including #08. To ensure compliance with this standard the following measures have been taken: 1. Resident #08 was assessed by the registered nurse and med review completed by 4/28/26. After review of resident's drug regime's, it was discovered that resident #8 had 2 separate medication recommendations on the same form, to be reviewed by two separate practitioners, pharmacy has been instructed and agreed to separate meds on individual forms. 2. Licensed nurses re-educated to facility policy "Drug Regimen Review" by Director of nursing/designee in April 2026 and no later than 5/8/26. Licensed nurses are responsible for ensuring the reviews and recommendations are given to the physician for timely review. 3. Review of all other current residents Drug Regimen orders completed by Director of nursing/designee on 4/16/26 to ensure recommendations were followed up on/reviewed by the physician and address concerns if needed. 4. Audit of drug regime recommendations, pharmacy recommendations, and physician follow up to be completed weekly for four weeks by the Director of nursing/designee. Administrator will present results of these audits to the QAPI committee for ongoing monitoring and further direction.
Untimely Response to Pharmacist Drug Regimen Review Recommendations
Penalty
Summary
The deficiency involves the facility’s failure to ensure that monthly drug regimen review (MMR) recommendations from the consultant pharmacist were reviewed and acted upon within the facility’s required timeframe of no later than 30 days. For one resident with insomnia, intellectual disabilities, muscle weakness, constipation, major depressive disorder, neuralgia, and neuritis, the medical record showed they were cognitively intact, receiving psychotropic medications, and care planned as being at risk for adverse side effects from antidepressants, anti‑anxiety medications, and sleep aids. The pharmacist made a recommendation on 06/24/25 for a gradual dose reduction (GDR) of trazodone 50 mg nightly, but the physician response of disagreement was not documented until 08/01/25. The pharmacist later recommended on 12/19/25 a GDR of amitriptyline 25 mg at bedtime to 10 mg nightly, with the physician’s agreement not recorded until 02/06/26. The DON and Administrator confirmed these pharmacy recommendations were not reviewed and acted upon in a timely manner, contrary to the facility’s drug regimen review and reporting policy dated 01/27/25, which requires all identified irregularities and recommendations to be acted upon no later than 30 days. A second cognitively intact resident with multiple chronic conditions, including COPD, peripheral vascular disease, chronic respiratory disease, type II diabetes, neuropathy, heart failure, hypertensive heart disease, morbid obesity, atherosclerotic heart disease, sensorineural hearing loss, muscle weakness, anemia, chronic kidney disease, major depressive disorder, atrial fibrillation, hyperlipidemia, and anxiety disorder, was also affected. For this resident, a pharmacy recommendation dated 12/19/25 called for a GDR of sertraline from 50 mg to 25 mg. The provider did not address this recommendation until 02/06/26, when they agreed with the dose reduction. In an interview, the DON confirmed that this pharmacy recommendation was not addressed within the expected timeframe and stated that they typically address pharmacy recommendations within a month of issuance, which did not occur in this case.
Failure to Timely Implement Pharmacy and Physician Discontinuation of PRN Hydroxyzine
Penalty
Summary
The deficiency involves the facility’s failure to ensure timely implementation of pharmacy recommendations to discontinue a medication after physician approval. A resident admitted with diagnoses including a displaced right humerus fracture, gait and mobility abnormalities, type II diabetes mellitus, morbid obesity, and chronic kidney disease had a physician order dated 01/27/26 for Hydroxyzine Pamoate 25 mg to be given orally once daily as needed. The five-day admission MDS showed a BIMS score of 10, indicating moderate cognitive impairment, and documented that the resident was receiving a diuretic, opioid, antiplatelet, and antidepressant. On 02/16/26, the consulting pharmacy recommended discontinuation of Hydroxyzine Pamoate 25 mg, and on 02/20/26 the physician reviewed and agreed with this recommendation, signing to discontinue the medication. Despite the physician’s discontinuation decision, review of the February and March 2026 MARs showed that the Hydroxyzine Pamoate order remained active and the medication continued to be administered. The MAR for February 2026 documented administration of Hydroxyzine Pamoate 25 mg on 02/25/26, and the March 2026 MAR documented administrations on 03/06/26 and 03/11/26. The order itself was not discontinued until 03/16/26. During an interview on 03/17/26, the Regional Nurse confirmed that the pharmacy recommendation to discontinue the medication was made on 02/16/26, the physician signed to discontinue it on 02/20/26, but the medication continued to be given on the above dates and the order remained in place until mid-March. Facility policy on medication administration stated that medications are to be administered in accordance with prescriber orders, which did not occur in this case.
Failure to Act on Pharmacist Drug Regimen Reviews and Orders
Penalty
Summary
The facility failed to ensure appropriate and timely response to pharmacist drug regimen reviews for two residents. For one resident with acute osteomyelitis, DM, PVD, CHF, and anemia, the pharmacist recommended on 12/09/25 that doxycycline administration be separated by at least two hours from magnesium oxide and ferrous sulfate to optimize absorption. The physician reviewed and signed this recommendation on 12/10/25. However, review of the December 2025 MAR showed the resident continued to receive doxycycline at 8:00 A.M. and 8:00 P.M., magnesium oxide at 8:00 A.M., and ferrous sulfate at 12:00 P.M., with no documentation that the magnesium oxide administration time was changed as recommended and ordered. The DON confirmed that staff had not changed the magnesium oxide administration time in accordance with the pharmacy recommendation and physician order. For another cognitively intact resident with type 2 DM, anxiety disorder, major depressive disorder, schizoid personality disorder, paraplegia, and malignant neoplasm of the breast, pharmacy recommendations dated 01/27/26 included a gradual dose reduction trial for amitriptyline and addressing two PRN lorazepam orders. The physician documented on the recommendation that dose reduction was contraindicated due to likely increased distressed behavior and added handwritten notes disputing the characterization of the resident as "psych." For the lorazepam recommendation, the physician renewed the duration of therapy for 14 days and again added handwritten notes referencing hospice and disputing "psych" labeling. The DON verified there had been no additional physician follow-up for these January 2026 pharmacy recommendations. Facility policy stated that physician recommendations from medication regimen reviews are to be distributed to the physician within two working days, reviewed within 30 days, and documented with actions taken or rationale for no change, with new orders transcribed and forwarded to pharmacy.
Plan Of Correction
F756 Drug Regimen Review. The PoC will what corrective action(s) will be accomplished for those residents found to have been affected by the deficient practice. Resident #2 recommendation for a change in magnesium order was not needed as the antibiotic that was a conflict is no longer ordered.MD notified 3/31/26. Resident #4 MD stated a dose reduction for amitriptyline is contraindicated and will not make a change at this time for fear of worsening of condition MD order 4/1/26. How will you identify other residents having the potential to be affected by the same deficient practice and what corrective action will be taken. Like residents, are residents in the facility who are reviewed by the pharmacy consultant. A sweep of the pharmacy recommendations in coordination with the medical director resulted in all recommendations have been reviewed and signed off on 3-26-26. The sweep went back to February 2026.conducted by ADON. What measures will be put into place or what systemic changes will you make to ensure that the deficient practice does not recur. DON and ADON in-service by corporate nurses to obtain follow-up to the pharmacy recommendations in a timely manner. Also, in-service to assist MD when the resident has a psychiatrist or counselor. In-service was done on 3-27-26. MD inservice by ADON on 4/1/26 to complete pharmacy recommendations timely. How the corrective action will be monitored to ensure the deficient practice will not recur. DON is auditing, starting 4/1/26, for completed responses with signatures from MD and nurses, follow-up to ensure all recommendations are responded to by MD within a week after receiving recommendations,and the pharmacy recomentations are written. monthly X2, and submitting findings to QAPI committee. If concerns are noted, DON will approach MD and ADON to correct the issue and to prevent further issues.
Failure to Follow Up on Pharmacy Recommendations
Penalty
Summary
The facility failed to ensure that a licensed pharmacist completed and followed up on monthly drug regimen review recommendations for Resident #55, whose diagnoses included multiple sclerosis, anxiety disorder, dementia, depression, and hypertensive heart disease. Review of the resident’s record and pharmacy recommendations showed that the pharmacist identified multiple medication issues, including a recommendation to clarify the status of Norvasc after hospital records indicated the resident should be receiving 5 mg daily, but there was no documented response from the prescriber and no documented follow-up by the facility. Additional pharmacy recommendations for Resident #55 identified Hydroxyzine HCL 50 mg every six hours as needed without a stop date, with a recommendation to discontinue the medication, add a stop date, or change it to scheduled dosing, and Donepezil 5 mg daily for dementia, with recommendations to consider increasing the dose to 10 mg at bedtime per manufacturer guidance. These recommendations also had no documented response from the prescriber and no documented follow-up by the facility. The DON confirmed in interview that the pharmacy recommendations were not responded to and should have been followed up on.
Delayed Review of Pharmacy Recommendations and Incomplete Medication Monitoring
Penalty
Summary
The facility failed to ensure that pharmacist medication regimen reviews were acted upon in a timely manner and that pharmacy recommendations were followed through in the medical record for three residents reviewed for unnecessary medications. For Resident #24, who had diagnoses including acute kidney failure, severe protein calorie malnutrition, COPD, atrial fibrillation, depression, anxiety, and weight loss, a pharmacy recommendation made on 10/21/25 to change Air Supra to albuterol inhaler was not transcribed until 12/01/25 after the order was written on 11/20/25. A later pharmacy review on 12/11/25 requested updated diagnoses for Protonix, folic acid, multivitamin, and vitamin D, but there was no evidence that this review had been addressed; the DON confirmed this during interview on 01/20/26. For Resident #7, who had diagnoses including diabetes, morbid obesity, adult failure to thrive, COPD, chronic respiratory failure, asthma, schizoaffective disorder, anxiety, depression, personality disorder, and PTSD, a pharmacy review on 10/22/25 questioned whether budesonide nebulizer should continue indefinitely since the resident also had Advair, but the January 2026 MAR still showed budesonide being administered twice daily. For Resident #32, who had diagnoses including paranoid schizophrenia, dementia, major depressive disorder, type II diabetes, hypothyroidism, hypertension, hyperlipidemia, dry eye syndrome, GERD, vitamin D deficiency, insomnia, and schizophrenia, the February 2025 MRR was not reviewed by the physician until 04/03/25, and a September 2025 pharmacy recommendation had no evidence of physician review or action. The record also showed AIMS assessments for Geodon were not completed every six months, with the last assessment on 06/25/25 and the prior one on 10/22/24.
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