Home Health & Hospice Week

For example: The patient’s preferred language may be a good thing to include, CMS suggests.

For the new OASIS items and measures on medication list transfers, one of the sticking points is what exactly constitutes a “current reconciled medication list.” The answer to that question may not be as clear as you’d hope.

In response to the 2020 proposed rule that introduced the measures and OASIS items, multiple commenters asked the Centers for Medicare & Medicaid Services to pin down that vital information, since agencies will have to give such lists to either the receiving provider or the patient/family/caregiver (see related story, p. 326).

On one hand: CMS doesn’t want to limit providers with a specific list of requirements. “Defining the completeness of the medication list is left to the discretion of the providers and patients who are coordinating this care,” the agency offers in the rule.

On the other hand: CMS would like to offer guidance. The rule defines “current reconciled medication list” as “a list of the current prescribed and over the counter (OTC) medications, nutritional supplements, vitamins, and homeopathic and herbal products administered by any route to the patient/resident at the time of discharge or transfer. Medications may also include but are not limited to total parenteral nutrition (TPN) and oxygen. The current medications should include those that are: (1) Active, including those that will be discontinued after discharge; and (2) those held during the stay and planned to be continued/ resumed after discharge. If deemed relevant to the patient’s/resident’s care by the subsequent provider, medications discontinued during the stay may be included.

“A reconciled medication list often includes important information about: (1) The patient/resident — including their name, date of birth, information, active diagnoses, known medication and other allergies, and known drug sensitivities and reactions; and (2) each medication, including the name, strength, dose, route of medication adminis­tration, frequency or timing, purpose/indication, any special instructions (for example, crush medications), and, for any held medications, the reason for holding the medication and when medication should resume. This information can improve medication safety. Additional information may be applicable and important to include in the medication list such as the patient’s/resident’s weight and date taken, height and date taken, patient’s preferred language, patient’s ability to self-administer medication, when the last dose of the medication was administered by the discharging provider, and when the final dose should be administered (for example, end of treatment).”

But CMS stresses multiple times that its suggested definition is not a requirement. “This is not an exhaustive list of the information that could be included in the medication list. The suggested elements detailed in the previous definition are for guidance purposes only and are not a requirement for the types of information to be included in a reconciled medication list in order to meet the measure criteria.”