CMS Addresses ASHP Concerns about Standing Order Protocols

10/29/2008

In response to concerns voiced by ASHP and others, the Centers for Medicare & Medicaid Services (CMS) has eliminated a requirement to obtain patient-specific practitioner approval for standing orders that meet CMS’s criteria prior to treatment.

In a memo issued last week, the agency noted that a guideline released in February 2008 had caused confusion about the use of standing orders in hospitals. The new communication makes clear that standing orders must be documented in a patient’s medical record, but the documentation should not interfere with timely patient care.

The guidelines also allow physicians to delegate tasks to pharmacists who practice under collaborative practice agreements authorized by state law.

CMS met with ASHP and other stakeholders this summer in response to an ASHP letter encouraging CMS to clarify the February guidelines. ASHP strongly cautioned the agency that its previous position might be interpreted to prohibit pharmacists from using established protocols and standing orders that reduce adverse drug events, improve patient care and lower costs.

The Joint Commission was among the stakeholders seeking clarification on the guidelines and has noted that the revisions "bring CMS’ interpretation of standing orders into alignment with The Joint Commission’s view on how to facilitate the timely treatment of certain patients, particularly those who need medications, not previously ordered, to be administered within brief timeframes."

The existing regulations still require orders for drugs to be signed by a practitioner. ASHP intends to take an active role in ensuring that current programs for pharmacist-initiated protocols are not threatened and will participate in CMS’s consensus-building efforts to advance safe practices for standing orders.

Click here to read the CMS memo.