Medication Reconciliation Questions

1.  How much of a risk do you anticipate existswhen they lack pharmacy review of preop and day surgery medication orders prior to administration?

Greeley Position and Rationale:

Not obtaining a pharmacist review of the order is considered to be low risk to patient safety as pre-operative medications typically are pre-printed orders with prior input from anesthesia providers and pharmacy.

Pharmacy review is not a requirement of medication reconciliation. Currently, MM.4.10 EP 1 requires pharmacy review when an LIP is not in control of the medication process. However, from information obtained from Joint Commission, we expect a revision to this standard. Also, this is not frequently cited by Joint Commission and in rare situations when it was, the citation was turned around during clarification.

In our experiences, the surveyors tend to focus on whether the medication reconciliation process is well defined and consistently implemented. We would recommend resources be preserved to enhance medication reconciliation and not in performing a pharmacist review of pre-operative medications which would add very little value to patient care.

2.  Should the home medication list be sent to pharmacy when initials orders are submitted for review?

Greeley Position and Rationale:

Yes, unless the home medications are available in an electronic version and can be viewed by the pharmacist. This is a requirement under MM.1.10 EP 2. The patient’s current medications is considered “minimum information” available to those involved in medication management.

Also, if pharmacists become involved in medication reconciliation (which is not required by very helpful in achieving compliance), they would need to see the home medications in order to compare them to the initially ordered admission medications.

3.  What methods are pharmacies using to file or safe keep the home medication list to use in subsequent reconciliations such as transfers? If the pharmacy does not maintain the list, does the home med list need to be present when orders are rewritten due to an internal transfer that requires med recon?

Greeley Position and Rationale:

No. The home medication list must be in the chart and available to the entire healthcare team, including pharmacy. Upon transfer within the hospital, this home list is automatically available to the entire health care team (most importantly, to the physician) in case the physician chooses to restart a home medication that had be previously held. The list need not be resent to pharmacy and the hospital need not require additional documentation of reconciliation upon internal transfer.

4.  The FAQ on page 15 requires a med list be provided to the patient when transferring to another facility. In practice, a medication list has been a part of transfer packets for many years. To give a copy to the patient/family seems a bit risky as they may keep it and consider it is their med list after arriving at the facility even after orders have been altered. Should we expect this to be done? It is not part of our model policy.

Reference

FAQs page 15: “The purpose of giving the list to the patient is to enable the patient to be involved in his/her care. When a patient is discharged from a health care organization, whether to home or to another health care organization, Goal 8B requires that the list be given to the patient or to whomever the patient might have designated for receiving such information.”

Greeley Position and Rationale:

Yes, and it probably is already being done. We often fail to remember that the patient has the right to view documents within their medical record. Because a medication list is a component of the patient transfer information that accompanies the patient to the next facility, the patient/family has received the list because they have ready access to the information.

Greeley’s medication reconciliation model policy will be revised to include a statement that the medical records containing the discharge medication list should accompany the transferring patient.

5.  Is a signature on the home medication list needed by the person who is entering the medication information? It is a permanent part of the record. We know JC doesn't require a signature related to med recon but what about as a document within the record? CMS requires record entries to be signed, dated and timed.

Greeley Position and Rationale:

The home medication list should be signed, dated and timed by the individual collecting the information in order to comply with Joint Commission and CMS regarding medical record entries. Any signatures on the form other than that of the person taking the medication history is not specifically required. The organization should consider how it will answer the question “How do you know that reconciliation / education took place?” We prefer that a solid, natural process be used to respond to such questions rather than requiring extra documentation.

The Greeley Company

200 Hoods Lane.● Marblehead, MA 01945 ● (888)749-3054

www.greeley.com

Page 1 of 2