March 2025

Any comments/suggestions please email the editor at editor@redrockrx.com

Edited by Malcolm Fraser MD, CMD

Upcoming Survey Process Changes: 

What You Need to Know

As of late February, it looks like the new Survey Process is set to go into effect on March 24 as scheduled.

The details are complex, and we anticipate significant regional variation in how the regulations are interpreted.

One thing that is certain is an INCREASED emphasis on surveyors closely monitoring the appropriate usage of atypical antipsychotics. This may involve mandated conversations with the Medical Director.

Two facilities we serve in Colorado have recently implemented an interesting concept that I believe will gain traction for two reasons:

• It reduces survey liability.
• It is the right thing to do for the resident.
  

The Concept:

• Whenever a provider orders a new atypical antipsychotic or increases the dose of an existing one, the Director of Nursing (DON) requests that the provider write an additional order placing a 24-hour hold on the new prescription.

• During this period, a thorough chart review is conducted to ensure all non-pharmacological options have been documented and exhausted. Remember, a late note is still a "good note." If this review determines that other options have not been fully explored, the DON requests that the provider cancel the new order while alternative interventions are attempted.

At survey time, nursing staff can confidently inform surveyors, "This is what we did before starting or increasing the antipsychotic." This approach significantly strengthens the facility’s position during the survey process.

If anyone else has ideas to share, please email our editor at editor@redrockrx.com.

Thank you.

Shixian Wang

Director of Operations

Employee of the Month: Tayler

Meet Tayler, Red Rock Pharmacy’s Employee of the Month for March! Tayler joined the Meridian, Idaho branch in September 2022 as a pharmacist, eager to expand her expertise in long-term care. Having previously worked for a smaller long-term care pharmacy, she saw Red Rock as the perfect opportunity to grow her knowledge and skills. Since joining, she has developed stronger leadership, multitasking, and time management abilities, while also deepening her clinical expertise—particularly in dosing and monitoring IV antibiotics.

One of Tayler’s favorite aspects of Red Rock is the company culture. She values the supportive environment and the sense of camaraderie among her colleagues, where teamwork and fun go hand in hand with providing exceptional care to the community. What motivates her each day is knowing that her work makes a real impact on people's lives. She believes in making the most of every day and takes pride in the responsibility of ensuring the best possible outcomes for patients.

Outside of work, Tayler enjoys staying active by playing volleyball, rock climbing, and hitting the gym as a way to relieve stress. When it’s time to relax, she unwinds with movies or TV shows and loves taking walks with her dog. And if she had to choose just one food to eat for the rest of her life? It might not be a full meal, but she could happily live off chips and salsa!

Congratulations, Tayler, on this well-deserved recognition!

Survey Update

As of February 2025, the most common nursing home citations are:

1. Infection Prevention and Control (F880): Persistent issues with infection control practices, including improper use of personal protective equipment (PPE) and inadequate hand hygiene. 
2. Accidents (F689): Inadequate supervision and failure to prevent avoidable accidents, such as falls and injuries.
3. Food Procurement, Storage, Preparation, and Service (F812): Deficiencies in food storage, preparation, or sanitation protocols.
4. Quality of Care (F684): Shortcomings in addressing residents’ physical, mental, and psychosocial well-being.
5. Comprehensive Care Plans (F656): Failure to keep care plans current or fully detailed.
6. Activities of Daily Living (ADLs) Care (F677): Inconsistent assistance with bathing, grooming, or dressing.
7. Resident Rights (F550): Deficiencies in respecting residents’ dignity, privacy, and personal choices.
8. Labeling and Storage of Drugs and Biologicals (F761): Issues with proper labeling and storage of medications.  

-Generated by ChatGPT 2/23/2025. For more details: Click Here

Customer Satisfaction Survey show excellent results! 

• 97% of our customers say we are easy to get ahold of
• 94% report a high-quality customer service experience
• 94% report 2 calls or less to solve any problem  
• 97% feel concerns were adequately addressed timely
• 97% of our current customers would encourage other companies to switch to Red Rock Pharmacy
• 97% of our current customers are satisfied with the speed and quality of our services.

Some of the areas our current customers liked about Red Rock the most included:

• Multiple deliveries daily
• Being open on weekends and Holidays
• Availability of pharmacy staff
• Ability to text with pharmacy staff
• Having local representatives
• Prompt follow up on concerns or issues 

Additionally, our error rate is significantly below the national average for 2024! Per PubMed, the national dispensing error rate was 1.6%. For 2024, Red Rock achieved an error rate of 0.02%, beating the national average by a wide margin. We take pride in helping our partners find pharmacy success and our Marketers visit our accounts often to ensure smooth operations.  

How can Red Rock help you achieve success this year? Please email me with suggestions at drimlinger@redrockrx.com.

Dave Rimlinger

Director of Marketing



New Survey process due to be initiated 3/24/2025

As previously mentioned, the new Survey Update is 902 pages long. The previous Survey Update in 2017 (the so-called Megarule Update) was only 550 pages long.

So, what are the key points? I (The RRR Editor) got a headache trying to figure it out until my wife (who is much smarter than me) suggested I ask ChatGPT.

This is what ChatGPT came up with (accessed 2/23/2025).

The Centers for Medicare & Medicaid Services (CMS) has announced significant revisions to its Long-Term Care (LTC) Surveyor Guidance, effective March 24, 2025. These updates aim to enhance the quality of care and ensure regulatory compliance in nursing homes. Key changes include:

Admission, Transfer, and Discharge:

• Admission Agreements: Prohibition of clauses requiring third-party payment guarantees.
• Transfer and Discharge Processes: Introduction of new F-tags (F627 and F628) to replace previous ones, removing the terms "facility-initiated" and "resident-initiated."

Chemical Restraints and Psychotropic Medications:

• F605: Consolidation of previous F-tags into F605, emphasizing the inappropriate use of psychotropic medications for staff convenience.

Professional Standards and Medical Director:

• Medical Director's Role: Clarification of responsibilities, including intervention when care deviates from standards and involvement in developing resident care policies.

Nursing Services and Payroll-Based Journal:

• Staffing Requirements: Emphasis on providing licensed nursing staff 24/7 and designating a charge nurse for each shift.
• Payroll-Based Journal (PBJ): Guidance on utilizing PBJ data to assess staffing compliance.

Resident Assessment and Quality Assurance:

• MDS Accuracy: Enhanced focus on accurate Minimum Data Set (MDS) coding, with potential referrals for falsification.
• Quality Assurance Performance Improvement (QAPI): Strengthened requirements for facility quality improvement programs.

Infection Prevention and Control:

• Evidence-Based Practices (EBP): Integration of EBP into infection control protocols.

COVID-19 Immunization:

• Documentation: Requirement for facilities to offer and educate staff and residents on COVID-19 vaccines, with proper documentation.

These revisions are detailed in the CMS memorandum QSO-25-12-NH, released in January 2025. Surveyors will begin using this guidance to determine compliance on surveys starting March 24, 2025.

Now you know as much as I do (and my wife!).

For more details: Click Here

Ozempic Update – Expanded Indications

• In February 2025, the Food and Drug Administration approved Novo Nordisk’s Ozempic for patients with both chronic kidney disease and diabetes, expanding the use of the wildly popular injection in the U.S.
• The FDA’s decision means Ozempic can be used to reduce the risk of kidney disease progression, kidney failure, and death from cardiovascular disease in patients with chronic kidney disease and diabetes.
• This decision could transform how doctors treat patients with the condition, which involves a gradual loss of kidney function and is one of the leading causes of death in the U.S.

The recent FDA decision follows a similar one in Europe, which was made late last year.

Why Is This Important?

Ozempic reduced the risk of severe kidney outcomes—including kidney failure, a decline in kidney function, or death from kidney or heart-related causes—by 24% in diabetic patients with chronic kidney disease compared to a placebo, according to the results of a late-stage trial that the approval was based on.

In patients who took Ozempic, kidney function declined more slowly, the risk of major cardiovascular events such as heart attack dropped by 18%, and the risk of death from any cause fell by 20% compared to the placebo. Ozempic also reduced the risk of cardiovascular-related deaths by 29%.

For more details: Click Here



Advisory Committee on Immunization Practices Updates Recommendations for Pneumococcal, RSV, and COVID Vaccinations

The 2025 Adult Immunization Schedule features several updates:

• Pneumococcal vaccination age recommendation lowered from 65 to 50 years old.
• A second dose of the 2024-2025 COVID-19 vaccine recommended for adults 65 years and older.
• Additional doses of the 2024-2025 COVID-19 vaccine recommended for immunocompromised individuals.
• New RSV vaccination guidance for all adults 75 and older and for adults ages 60–74 at increased risk of severe RSV disease.

Pneumococcal Vaccine Reminder

Always use the CDC RX App (available for iPhone and Android) to ensure proper vaccine recommendations.

For more details: Click Here

Updated Treatment Goals for Hypertension – New Target: Systolic BP Below 120

This update is important for our friends, relatives, and patients/residents in Assisted Living Facilities (ALF) and Nursing Homes (NH).

What Are the Target Numbers for Treating Hypertension?

A new study shows that patients over age 65 with a systolic blood pressure (BP)—the higher of the two numbers—below 120 fare better than those treated to the traditional target of around 140.

The study included over 5,000 participants aged 65 and older and found a significant reduction in risk when treating to a systolic BP target of <120 mmHg compared to <140 mmHg. Benefits included:

• Lower all-cause mortality
• Reduced risk of cardiovascular events
• Improved cognitive outcomes
• Fewer serious adverse events

The net benefits were analyzed across different age groups (65–74 vs. ≥75 years).

Key Takeaway

Among community-dwelling older adults with hypertension in the study (SPRINT), almost all participants experienced greater benefits with a systolic BP target of <120 mmHg. However, the magnitude of benefit varied based on individual risk factors and patient preferences.

Editor’s Note: Never change any prescription medications without first consulting your healthcare provider (HCP).

For more details: Click Here



Editor’s Column

If I Were a Surveyor…

If I were a Surveyor, these are the questions I would ask a Medical Director concerning the use of antipsychotics in a nursing home:

1. Doctor, which types of antipsychotics are used most often in this nursing home? (Note: This question includes all antipsychotics, such as Haldol—not just the newer atypical ones like Seroquel.)
2. Doctor, how does the use of antipsychotics in your nursing home compare with state and federal averages? (I would expect the Medical Director to say: “I don’t know, but I will request a report.”)
3. Doctor, how often are Psychotropic Gradual Dose Reduction (GDR) meetings held, who attends them, and how do you participate in the process? (If the Medical Director responds, “What is a GDR meeting?”—that’s a problem!)

Regulatory Considerations

Federal regulations state that the Medical Director is responsible for the overall coordination of care, not just the care of individual residents.

One area of liability that has historically been overlooked is when the Medical Director also serves as an Attending Physician. According to federal regulations:

Sec: 483.70(h) – Medical Director as the Attending Physician

If the Medical Director is also an Attending Physician, there must be a process in place to ensure no conflicts of interest exist regarding their performance. If concerns arise about their clinical performance, the facility’s administration must have a clear plan for addressing them.

Additional Questions for the Medical Director

4). Doctor, do you provide Attending Physician services to any residents in this nursing home?

• If the answer is “Yes,” follow up with:

5). Doctor, what written arrangements have you made to ensure independent review of any concerns regarding your clinical performance?

Surveyor Expectations & Possible Solutions

Surveyors will likely expect an additional level of review regarding the appropriate use of antipsychotics when the Medical Director is also an Attending Physician. Possible solutions may include oversight from a Regional Medical Director, Clinical Consultant, or a Remote Physician Advisor. Time will tell how these expectations evolve. 

As always, your RR Pharmacist will keep you updated.