ASCP Received Emerging Details From CMS

On November 9, ASCP sent an email to members detailing potential changes to the medication crushing guidelines in Appendix PP of the State Operations Manual. At that time, we had not received confirmation of the changes from CMS. ASCP has now received an official correspondence from the Office of Survey and Certification at CMS regarding oral administration of crushed medications:

“Thank you for your question asking for clarification of guidance on administering crushed oral medications.

We have received a number of questions about crushing and combining oral medications into food since we released the draft version of Appendix PP in June of this year and we appreciate the concerns that have been expressed regarding the time and effort required to separate crushed medications for oral administration.

We will be revising the interpretive guidance to convey that best practice would be to separately crush and administer each medication with food to address concerns with physical and chemical incompatibility of crushed medications and ensure complete dosaging of each medication. However, separating crushed medications may not be appropriate for all residents and should not be counted as a medication error unless there are instructions not to crush the medication(s). Facilities should use a person-centered, individualized approach to administering all medications. If a surveyor identifies concerns related to crushing and combining oral medications, the surveyor should evaluate whether facility staff have worked with the resident/representative and appropriate clinicians (e.g., the consultant pharmacist, attending physician, medical director) to determine the most appropriate method for administering medications which considers each resident’s safety, needs, medication schedule, preferences, and functional ability.

CMS is also revising the facility task for Medication Administration Observation, CMS 20056 to reflect this change, before the release of these materials in final form on November 28, 2017. Interpretive guidance related to crushed medications administered via feeding tube will remain unchanged.”

We understand that the final version of Appendix PP Interpretive Guidelines, including the updated information regarding medication crushing, will be released by CMS on or before 11/28/17. As ASCP receives any additional information we will continue to keep our members informed.

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Curt Wood, R.Ph., FASCP

Board Certified Geriatric Pharmacist

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