The CMS Medication Regimen Review: An Introduction
Jeannine LeCompte, Compliance Research Specialist
The Improving Medicare Post-Acute Care Transformation Act of 2014 (IMPACT Act of 2014) requires all skilled nursing facilities to report standardized patient assessment data—including the “Medication Regimen Review,” or MRR (also known as Drug Regimen Review, DRR) quality measure.
The MRR includes a review of all medications a patient is currently using, including prescribed and over the counter (plus total parenteral nutrition and herbals), administered by any route (e.g., oral, topical, inhalant, pump, injection, intravenous, and via enteral tube).
It consists of a thorough evaluation of the medication regimen of a resident, with the goal of promoting positive outcomes and minimizing adverse consequences and potential risks associated with medication; a review of the medical record in order to prevent, identify, report, and resolve medication-related problems, errors, or other irregularities, and involves collaborating with other members of the interdisciplinary team, including the resident, their family, and/or representative.
The MRR process requires that three conditions are met:
- Completion of a drug regimen review at the beginning of the care episode;
- Physician contact and follow-up if medication issues are identified at start of care/resumption of care; and
- Physician contact and follow-up each time significant medication issues are identified throughout the care episode.
According to Title 42 (the principal set of rules and regulations issued by federal agencies of the United States regarding public health), and §483.45(c), in particular, the drug regimen and medical chart of each resident must be reviewed at least once a month by a licensed pharmacist.
Any irregularities noted by the pharmacist during this review must be documented in a separate, written report that is sent to the attending physician, director of nursing (DON), and the facility’s medical director. It should list, at a minimum, the resident’s name, the relevant drug, and the irregularity the pharmacist identified. It is a legal obligation that these reports are acted upon.
The attending physician must document in the resident’s medical record that the identified irregularity has been reviewed and what, if any, action has been taken to address it. If there is to be no change in the medication orders, the attending physician should document his or her rationale in the resident’s medical record.
The intent of this requirement is that the facility maintains the resident’s highest practicable level of physical, mental, and psychosocial well-being and prevents or minimizes adverse consequences related to medication therapy to the fullest extent possible, by providing oversight by a licensed pharmacist, attending physician, medical director, and the DON.
