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Lifting a Regulatory Burden Could Create Dangerous Consequences

Cheryl Clark, for HealthLeaders Media, November 17, 2011

As someone who has visited family members and others in the hospital, I also can envision the problems relaxing this rule could present.  A son, a daughter, and a wife all know about Tom Smith's need for a certain daily pill. And when they all visit him in the hospital, they all make sure he gets it.  But they all visit him at different times. Then the nurse comes to administer it again.

Mr. Smith might object, but hospitalized patients often get confused over the shock of their new surroundings, even if they otherwise would have the capability of remembering what their dosage should be.

And in any case, physicians evaluating his care may ultimately discover those medications might be the very ones causing some of his medical problem, or are contraindicated.

Richard Bankowitz, MD, chief medical officer for the quality and purchasing healthcare network Premier Healthcare Alliance, sees both sides.

On one hand, he says, the rule "is "meant to balance the fact that as patients are admitted to the hospital, many of them are on chronic medications that need to be taken at a certain schedule," he tells me in an interview. "There's been some concern that as soon as patients come into the hospital their medications get taken away and then they've got to wait for the orders to be written and the medications to come up from the pharmacy. ... It could be very frustrating."

Providing better medication continuity would be a good thing, he says.

On the other hand, allowing patients to keep and administer their own medications comes with some risk, he acknowledges. "The flip side is that there's a documentation issue, so even if it's just one family member, what happens then if the nurse comes by with the medication, and it's not documented in the chart because the family hasn't accessed the medication record and recorded that the medication was given?"

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1 comments on "Lifting a Regulatory Burden Could Create Dangerous Consequences"


Mark Dominesey (11/30/2011 at 8:32 AM)
There clearly two very important sides to this issue. One issue is the patient is trusted to administer the medication (or have someone else administer it for them) while they are out of the hospital, and allowing them to continue that practice can help alleviate some of their anxiety and promote a sense of partial independence. The other issue is that now the hosptal and the clinicians may be required to take responsibility for something that they did not do, or have little control over. The article takes a negative tone for allowing patient administered medications after it does a wonderful job of laying out how clinicians and hospitals can alleviate some culpability. The CMS guidelines appear to be vague enough to allow the hospitals some flexibility in creating policies (in consultation with their Risk Management Dept) that will delineate when this pratice should be allowed and when it should not be. Patient and caregiver education is key to this practice and patient education was not mentioned in the article. Yes, there are very real possibilities of patient harm if certain medications are administered more than what is therapeutically efficacious, but hospitals can craft policies and procedures to mitigate those risks. At no time should patient self-administration be implemented to alleviate some burden on clinicians or for clinician convenience, but only as a vehicle to promote patient independence and wellness. I am in favor of this proposal by CMS. Patient self-administration does occur now, though not widespread, in many hospitals, with a properly [INVALID]d physician order and patient education. Many medications are not suitable for this proposal and it would behoove the hospitals to include such language in their ploicies and procedures along with assistance from their pharmacy staff.