CMS Revises Guidance Related to Improving Care for Persons with Dementia and Reducing Antipsychotic Drug Use in Nursing Facilities

The Centers for Medicare & Medicaid Services (CMS) has released two new Survey and Certification Memos revising guidance on care for persons with dementia, consistent with the goals of the Partnership to Improve Dementia Care in Nursing Homes to, “optimize quality of life and function of residents in America’s nursing homes by improving approaches to meeting the health, psychosocial and behavioral health needs of all residents, especially those with dementia.”  The new guidance emphasizes the need to individualize care and treatment approaches and to ensure that antipsychotic medications are used only when a clear and appropriate clinical indication exists.

S&C:13-35-NH references revisions to surveyor guidance for F-tags 309 (Quality of Care) and F-329 (Unnecessary Drugs).  CMS notes that this revised guidance highlights and re-emphasizes key principles in the nursing facility regulations including:

  • Person–Centered Care
  • Quality and Quantity of Staff
  • Thorough Evaluation of New or Worsening Behaviors
  • Individualized Approaches to Care
  • Critical Thinking Related to Antipsychotic Drug Use
  • Interviews with Prescribers
  • Engagement of Resident and/or Representative in Decision-Making

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. This checklist is not part of the SOM.

The second memorandum, S&C: 13-34-ALL, provides information about the third and final training video in the three-part series of mandatory surveyor trainings CMS has prepared on this topic.  The first two modules of the training program were released earlier this year. This third installment of the training instructs surveyors in how to cite severity level and other aspects of deficiency citations in more detail, based on the new guidance at F309, Care of Residents with Dementia, and revised guidance at F329 referenced in S&C: 13-35-NH.  This training module is 35 minutes in length.  The memorandum provides instructions for accessing this content.