Pharmacist Guide to CMS Survey

Pharmacist Survival Guide for Center for Medicare & Medicaid Services (CMS) Visit for Transplant Program - A Colorado Experience
by Ike Kim, PharmD, BCPS
CMS Survey team was very cordial and was honest about what is required of pharmacist in the care of transplant patient. It boils down to documentation, documentation, and documentation! According to CMS surveyors, there are no specific guidelines for pharmacists other than that the pharmacist be involved in the care of the patient. There is no specific language spelt out as to what needs to be done by the pharmacist in the care of the patient. The recommendation by the survey team is basically composed of pre-transplantation evaluation documentation, first progress note immediately post-op, second post-operative pharmacy progress note before the discharge and a clinic note after the discharge. The clinical documentation can be one sentence or whole page, but it needs to readily reproducible for inspection by the CMS surveyors. Another important piece of the puzzle is that the pharmacist never needs to see the patient in person, but this is nearly impossible.
1) Pre-transplant evaluation: What the surveyors wanted to see was at least one documentation during pre-transplantation evaluation period that can span anywhere from days to years. This requirement can be easily met as a part of selection committee meeting minutes as long there is a single sentence that says “no pharmacy-related problems were noted” for every patient.
2) First post-operative note: For us, this note included home medication reconciliation, nature of the drug allergies, whether the patient is experiencing transplant medication-related complications, pain relief provided by PCA or other pain medications, whether patient is being covered for PCP and CMV prophylaxis, and bowel regimen.
3) Second pharmacy progress note: We made this simple by inserting a pre-printed check off boxes for patient education as listed below.
4) Clinic Note Documentation: This note includes compliance, cyclosporine or tacrolimus levels, whether the patient is experiencing medication-related complications or toxicities.
The bottom line:
The main idea of requiring pharmacist in the care of the patient is to address medication-related complications.
I hope this short guideline helps those of you being visited by the CMS survey team.
Good luck!
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