CMS rewrote 10 of the 18 tag hospital pharmacy sections November 20, 2015 and hospitals are still struggling with compliance. There has been increased scrutiny of the standards and an increase in the number of deficiencies for hospitals. This should be on the radar screen of all hospitals. This include changes regarding compounding of medication and the beyond use date (BUD) and to bring them into alignment with the acceptable standards of practice. Language was included to allow the surveyor to cite the hospitals at either the standard or condition level. The proposed changes under the Hospital Improvement Rule will be discussed. This will require hospitals to have an antibiotic stewardship program. There have been many recent changes in the nursing section that address medication usage also. This includes changes to timing of medication, self administered medication, compounding, blood, and safe opioid use. There are three time frames that medications must be administered along with the QAPI requirements. These will be provided as additional resources. There will also be additional resources. The OIG recommended surveyor training and the evaluation of 55 things in addition to revising the pharmacy standards which was done. Did you know the most common medical error in hospitals today is medication errors? CMS said that drug related adverse outcomes occur in 1.9 million inpatient stays which is almost 5% of all admissions. There are also 838,000 patients a year who are treated as an outpatient who have a drug related adverse event. Hospitals that spend more resources on medication issues generally have lower rates. Just about every hospital in America accepts Medicare and Medicaid reimbursement and as such must follow the Center for Medicare and Medicaid Services (CMS) hospital interpretive guidelines. These regulations and interpretive guidelines must be followed for all patients in the hospital. Information will be provided on the top problematic pharmacy standards by CMS. CMS is now issuing a deficiency report showing when the pharmacy is cited for being out of compliance. This program is a must to help ensure compliance with the hospital CoPs. It is important for the nursing to understand the medication and pharmacy standards since many of them apply to nursing. For the first time, CMS mentions that nursing needs to be aware of some of the pharmacy standards and vice versa. This includes medication errors, adverse events, and drug incompatibilities, self-administered medication and required medication policies. If a medication error or ADE occurs there must be notification of the physician, documentation in the medical record and it must be included in the PI data. The timing of medication requires policies and procedures and training by hospitals. This section requires notification of the physicians and discusses when this must occur. Hospitals should have a non-punitive approach and the definition of medication error should be broad enough to include near misses. The CMS interpretive guidelines address medication management and pharmacy related standards. These can be looked at when CMS conducts a complaint or validation survey. Medication management is not only a big issue with CMS but also with the Joint Commission. Medication errors are the largest number of medical errors in healthcare today. They are also the most common reason for unnecessary readmissions to the hospital. It is essential that hospitals work together to implement and follow these regulations. Problematic standards include verbal orders for medication, order for medications, and standing orders.

• Recall that all hospitals that receive Medicare/Medicaid reimbursement must follow the medication guidelines for all patients

• Discuss that CMS has requirements on BUD and compounding

• Recall that CMS has a number of required pharmacy policies and procedures

• Describe that CMS requires a policy for high risk drugs such as double checks or dose limits.