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CMS F-Tags, F-329 Unnecessary Medications; The Most Commonly Cited Meds

I’ve spent years of my life working in and around long term care (nursing homes).  The CMS F-tag, F-329 Unnecessary Medications tag is by far (in combination with F-428) the most common survey deficiency that a consultant pharmacist can help a facility avoid. The F-tags have been changed, get the update at LTCPHARMD.com – my new website specifically dedicated to medication management in long term care.

F-329 Unnecessary Medications is a broad classification: Per CMS guidance, an unnecessary medication is any medication that is;

  1. In excessive dose (including duplicate therapy); or
  2. For excessive duration; or
  3.  Without adequate monitoring; or
  4.  Without adequate indications for its use; or
  5. In the presence of adverse consequences which indicate the dose should be reduced or discontinued; or
  6. Any combinations of the reasons above.

By definition any medication can be tagged as a potentially unnecessary medication, but which ones should you pay closer attention to in regards to F-329, and which ones are most frequently cited?

  1. Antipsychotics. These medications have a black box warning for use in elderly patients with dementia related behaviors.  Not only that, but they have no FDA approved indication to help with these behaviors.  My advice; you had better have really good reasoning, minimized the dose, and have ruled out every possible cause of the behaviors you can think of prior to initiating an antipsychotic.  Surveyors are trained to ensure antipsychotics are not being used inappropriately in our geriatric/LTC patient population.
  2. Antidepressants. While not quite as much of a lightning rod as the antipsychotics, you’ll find that they are used much more often than antipsychotics.  This leaves them in a position to potentially be cited under F-329 if not appropriately monitored and assessed.  Consistent, good documentation of benefit from the staff and providers can go a long way in helping you avoid an unnecessary medication deficiency.
  3. Benzodiazepines. These drugs can have a lot of negative side effects, particularly in the elderly.  Ensuring safety and benefit is of high importance if this class is to be used long term.  Documentation is another essential piece of the puzzle here as well.
  4. Sleepers. Any drug for sleep needs to be documented on a quarterly basis.  This can be a challenging task for busy providers and staff.  As a consultant pharmacist, you can help the facility stay out of trouble by ensuring that non-drug interventions have been tried and failed, other medications and medical conditions have been ruled out, and that any sleeper being utilized is providing benefit in the absence of side effects.

Looking for more insider tips on F-329 and medication management in long term care?  Get instant access to my one of a kind, 10+ hour online course that teaches pharmacists and other healthcare professionals about long term care!

Written By Eric Christianson

June 4, 2017

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