Consultant Pharmacists and the Survey Process

Abstract

The State Operations Manual (SOM), published by the Centers for Medicare and Medicaid Services (CMS), describes the nursing facility survey process that is the primary regulatory focus for facilities. CMS is now revising several sections in Appendix PP of the SOM that contains the Interpretive Guidelines for Long-Term Care Facilities; some of these guidelines have already been released. The pharmacy-related sections of these guidelines are due out later this year. Because these revisions will affect the survey process, expectations of health care providers, and possibly the care process within nursing facilities, consultant pharmacists and all members of the interdisciplinary care team need to start preparing for these revisions. The information provided here is meant to be a refresher of the components of the survey process as a preliminary step in the preparation for the release of new guidelines.