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In November 2024, the Centers for Medicare and Medicaid Services (CMS) released Revised Long-Term Care (LTC) Surveyor Guidance. The memo included significant changes to guidance in Appendix PP. These changes are now effective starting March 24, 2025. This date change was just announced today.
CMS is incorporating the guidance for F758, Unnecessary Psychotropic Medications into F605, and revising F757, Unnecessary Medications to only include guidance for non-psychotropic medications. The revised F-tags F757, Unnecessary Medications; F605, Chemical Restraints/Psychotropic Medications; and Medication Regimen Review Critical Element Pathway (CEP) also include investigative elements to align with the revised guidance.
Additional takeaways include the following:
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The guidance regarding “convenience” has been revised to include situations when medications are used to cause symptoms consistent with sedation and/or require less effort by facility staff to meet the resident’s needs. The updated definition states “convenience refers to the unnecessary administration of a medication that causes (intentionally or unintentionally) a change in a resident’s behavior (e.g., sedation) such that the resident is subdued and/or requires less effort from staff. Therefore, if a medication causes symptoms consistent with sedation (e.g., excessive sleeping, drowsiness, withdrawal, decreased activity), it may take less effort to meet a resident’s behavioral needs, which meets the definition of convenience.”
- Guidance has been added to emphasize requirements related to the right of a resident to be fully informed and participate in or refuse treatment, noting that before initiating or increasing a psychotropic medication, the resident must be notified of and have the right to participate in their treatment, including the right to accept or decline the medication.
- Comprehensive documentation is a critical piece for compliance with these changes, including obtaining the necessary hospital or community records to support the resident’s medical history.
CMS also directs surveyors to confirm that documentation is included in the resident’s record of a comprehensive assessment and any behavioral (nonpharmacological interventions attempted, along with any medical contraindications. For additional information AHCA’s F-Tag Action Tool-F605 Right to be Free from Chemical Restraints contains a list of necessary resident medical record documentation and a check list of action items your facility can take to ensure regulatory compliance.
AHCA has also developed an on-demand webinar that walks learners through each of the changes to guidance, the updates to the Critical Element Pathways (CEP), and provides some tips/action items to be compliant ahead of the effective date. Available free to AHCA/NCAL members and $65 non-members. Please send questions to regulatory@ahca.org, and email educate@ahca.org if you need assistance with registering.
Thank you to AHCA for the development of the information contained within this communication and the associated tools. If you have questions, please contact Elena Madrid, Executive Vice President of Education and Regulatory Affairs.
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