Requirements for the Development of Medication Regimen Review (MRR) Policies and Procedures
Jeannine LeCompte, Compliance Research Specialist
Title 42, §483.45(c)(5) of the Act which governs Public Health, states that as part of the Medication Regimen Review (MRR) process, all facilities must develop and maintain policies and procedures for the monthly drug regimen review that include, but are not limited to:
– time frames for the different steps in the process; and
– steps the pharmacist must take when he or she identifies an irregularity that requires urgent action to protect the resident.
The pharmacist performing the monthly MRR must also review the resident’s medical record to appropriately monitor the medication regimen and ensure that the medications each resident receives are clinically indicated.
Certain circumstances may also increase the risk of adverse consequences, such as residents who have multiple medical conditions, concurrent administration of certain medications, administration of medications which require close monitoring through lab work, and transitions of care.
A review of the medical record as part of the MRR may prevent errors due to drug-drug interactions, omissions, duplication of therapy, or miscommunication during the transition from one team of care providers to another.
The policy should allow for the possibility that it may be necessary for the pharmacist to conduct the MRR more frequently than once a month, depending on the resident’s condition and the risks for adverse consequences related to current medications.
MRR policies and procedures should also address, but not be limited to:
– MRRs for residents who are anticipated to stay less than 30 days;
– MRRs for residents who experience an acute change of condition and for whom an immediate MRR is requested after appropriate staff have notified the resident’s physician, the medical director, and the director of nursing about the acute change.
Some indications of medication irregularities (such as symptoms of tardive dyskinesia, dizziness, anorexia, or falls) may be ascertained only by talking to the staff, and/or observing and speaking with the resident.
Other sources can include the medication administration records (MAR); prescribers’ orders; progress, nursing, and consultants’ notes; the Resident Assessment Instrument (RAI); laboratory and diagnostic test results, and other sources of information about documented expressions or indications of distress and/or changes in condition.
The policy should allow for the review of issues such as whether the physician and staff have documented objective findings, diagnoses, symptom(s); whether the physician and staff have identified and acted upon, or should be notified about, the resident’s allergies and/or potential side effects; whether the medication dose, frequency, route of administration, and duration are consistent with the resident’s condition, manufacturer’s recommendations, and applicable standards of practice, and whether there has been documented progress toward, decline from, or maintenance of the resident’s goal(s) for the medication therapy.
The policy should also be able to determine if staff have obtained and acted upon laboratory results, diagnostic studies, or other measurements (such as bowel function, intake, and output).
If any medication errors exist, the policy should also be able to determine if staff have noted and acted upon such indicators.
The facility should also have a procedure to resolve situations where the attending physician does not concur with or take action on identified irregularities, and where the attending physician is also the medical director.
