CMS Survey & Certification Memorandum 13-35-NH – Dementia Care and Reduction of Antipsychotic Drug Use

CMS released S&C 13-35-NH that clarifies Appendix P and Appendix PP of the State Operations Manual.  These revisions are to the surveyor guidance and re-emphasize key principles in nursing facility regulations.  Updates to Appendix P include changes to the resident sampling process for the traditional survey (changes to QIS were included in the recent 10.1.3 release), intended to ensure that the survey sample includes an adequate number of residents with dementia who are receiving an antipsychotic medication. 

Updates to Appendix PP include:
•             A new section of interpretive guidance at F309 related to the review of care and services for a resident with dementia;
•             Revisions to the antipsychotic medication section of Table 1 at F329;
•             New severity example at the end of the interpretive guidance at F329 (Unnecessary drugs);
 
A surveyor checklist that may be used in either the traditional or QIS process (modeled after the Critical Element pathways) is also provided  in the memorandum. This checklist is not part of the State Operations Manual.  To access the memorandum, go to http://www.cms.gov/Medicare/Provider-Enrollment-and-Certification/SurveyCertificationGenInfo/Policy-and-Memos-to-States-and-Regions-Items/Survey-and-Cert-Letter-13-35.html?DLPage=1&DLSort=2&DLSortDir=descending (as of May 28, 2013, the advance copy of the memo has not been posted, but when it is it will be at this link).