AGING AND DISABILITY SERVICES ADMINISTRATION

2006 NH "Dear Administrator" Letters

November 30, 2006

ADSA: NH #2006-030
NEW IMMUNIZATION REGULATION &
Changes in Significant Medication Error Guidance

Dear Nursing Facility/Home Administrator:

The federal Centers for Medicare and Medicaid Services (CMS) issued a new immunization regulation and survey protocol for implementation October 1, 2006. They have also issued clarification for citations regarding significant medication errors, effective immediately. The following provides a brief summation of the changes.

F334- Influenza and Pneumococcal Immunizations:

• New regulatory language, which does not conflict with state law.
• Changes to entrance conference requests. When conducting surveys outside of the Influenza Season (Oct.-Mar) surveyors will request a list of residents who were in the facility during the previous influenza season in accordance with the changes to Task 2 of the survey process.
• New Surveyor Investigative Protocol.

F333- Significant Medication Errors:

• The surveyor may now cite “Significant Medication Errors” without having observed the error during the survey task of medication pass observations. If a significant medication error is found through record review during a full survey or complaint survey it may be cited without having to have been identified through observation of medication pass.

You will recall that the 2002 state legislature passed a law related to providing residents information about the availability of flu and pneumonia immunizations in nursing homes. You can access the law and corresponding code, Revised Code of Washington (RCW) 74.42.285 and Washington Administrative Code (WAC) 388 -97-143 on line at: http://www1.leg.wa.gov/legislature.

For additional information on the CMS changes you can access the applicable memorandum (S&C 06-24 and S&C 06-30) on the CMS website at: http://www.cms.hhs.gov/.

If you have any questions regarding implementation, please contact your RCS Field Manager.

Sincerely,

Joyce Pashley Stockwell, Director
Residential Care Services