In response to released guidance for Requirements of Participation (RoP) Phase 3 and updates for Phase 2, the American Health Care Association (AHCA) is providing focused information to help skilled nursing facilities remain in compliance and avoid any failed practice. We give special thanks to the AHCA Survey and Regulatory staff for compiling and distributing this information. Elena Madrid, WHCA's Executive Vice President for Regulatory Affairs, co-chairs the AHCA Survey and Regulatory Committee and is a member of AHCA's Quality Cabinet.

§483.45 Pharmacy Services
CMS has revised the §483.45-Pharmacy Services guidance. Changes include the following: 
  • F755-Pharmacy Services: CMS provided clarification language related to the disposal of Fentanyl patches. 
  • F757-Drug Regimen is Free from Unnecessary Drugs: CMS added language related to antibiotic stewardship and F881. 
  • F758-Free from Unnecessary Psychotropic Medications/PRN Use: CMS provided clarification of other classes of drugs not listed in the regulation and how they are affected by the psychotropic medication requirements. CMS also added language on potential misdiagnoses, such as schizophrenia, in order to prescribe antipsychotics. 

Detailed information can be found in the Appendix PP-State Operations Manual. AHCA has also prepared an Action Brief. Additionally, as a member of WHCA and AHCA, you can access a full summary prepared by AHCA. If you have any questions, please email me or call me at (800) 562-6170, extension 105.