Module 3: The Drug Regimen Review - College of Pharmacy ...

7. Methods used to document chart irregularities when consultant intervention is not
required.
8. The do’s and don’ts of writing effective comments to the prescriber
I. THE MEDICATION REGIMEN REVIEW
Prior to the 2006 Interpretive Guidelines, there was no official HCFA or CMS definition for
“Drug Regimen Review” or “irregularity”. Survey guidelines over the past 27 years have
provided the surveyors a list of drug related issues to address. These indicators were designed to
help the surveyor determine whether the consultant was providing an adequate drug regimen
review. In many cases, surveyors used these guidelines as a checklist to measure the consultant’s
performance. Consultants followed their lead and used these same indicators to perform the
DRR. Irregularities that fell outside of those identified in the Interpretive Guidelines were often
not addressed in the drug regimen review.
The 2006 Interpretive Guidelines finally give us definitions for both the Medication Regimen
Review and an Irregularity.
“Medication Regimen Review” (MRR) is a thorough evaluation of the medication regimen by a pharmacist, with the
goal of promoting positive outcomes and minimizing adverse consequences associated with medication. The review
includes preventing, identifying, reporting, and resolving medication-related problems, medication errors, or other
irregularities in collaboration with other members of the interdisciplinary team.
The definition of Irregularity changed during different drafts of the Interpretive Guidelines. In
the 2 nd draft released in August 2005 Irregularity was defined as:
“Irregularity” – refers to any event related to the ordering, acquiring, dispensing, receiving, storing, controlling,
timing, administration, documentation, reporting, or monitoring of a medication, which can actually or
potentially interfere with the intended outcome for a resident and can include, but is not limited to a medication
related problem.
When the final Interpretive Guidelines were released in December 2006 the language was
softened to:
Irregularity” refers to any event that is inconsistent with usual, proper, accepted, or right approaches to
providing pharmaceutical services (see definition in F425), or that impedes or interferes with achieving the
intended outcomes
of those services.
Many consultants have focused their efforts on the medication regimen review and have
delegated M.A.R. audits, control reconciliation and physical inspections to nursing or support
staff. In addition, consultants may have chosen to use one part of the patient’s record, such as
the Physician Order Sheet, as their primary source for the chart review.
While it could be argued that this did not meet the intent of the old Interpretive Guidelines, it
seems clear that this practice falls far below the intent of medication regimen review as defined
in the 2006 Interpretive Guidelines.
Problems with ordering, storage, administration or documentation may now become part of the
medication regimen review since these are now defined as “irregularities”. The consultant who
previously ignored issues with timely ordering and delivery, “out of stock” medications or
occasional charting omissions will now be required to document these “irregularities” unless