Emergency Medication Requirement Change: QSO-19-18-RHC

CMS has allowed RHCs to determine which Emergency Meds are appropriate for the RHC.  These are stated in 42 CFR 491.9(c)(3).  This includes the following: “analgesics, anesthetics (local),antibiotics, anticonvulsants, antidotes and emetics, serums and toxoids.”  This is an extremely dated medication list – think 1977.  Most of us do not know what serums and toxoids are?

I have NEVER been to an RHC that had used, or were glad they had, an anticonvulsant.  It is stocked for the survey.  It never is used.  The medication expires.  It gets replaced, to never be used again.

There was a recent controversy over whether RHCs must stock snake venom antidote.  Even if there was not a specific risk in the RHC’s geographic area of snake bite.  Now we have the answer. We do NOT have to store snake venom antidote.

On September 3, 2019, the Centers for Medicare and Medicaid Services (CMS) released  “Revised Rural Health Clinic (RHC) Guidance Updating Emergency Medicine Availability—State Operations Manual (SOM) Appendix G- Advanced Copy.

Summary:  The Centers for Medicare & Medicaid Services (CMS) is updating the medical emergency guidance as it pertains to the availability of drugs and biologicals commonly used in life saving procedures.

Your Emergency Medication policy should be re-written to include consideration of each of the medication groups listed in 491.9(c)(3).  After considering each of these, state which medications will be stored.  It should also be documented who made the final decision.  This would preferably be the RHC Medical Director and/or NP/PA.

The updated text says:

“…when determining which drugs and biologicals to have available in order to provide medical emergency procedures as a first response to common life-threatening injuries and acute illness es, an RHC must consider each of the categories listed in regulation.

While each category of drugs and biologicals must be considered, all are not required to be stored. An RHC must have those drugs and biologicals that are necessary to provide its medical emergency procedures to common life-threatening injuries and acute illnesses.

In making this determination, the RHC should consider, among other things, accepted medical standards of practice, community history and the medical history of its patients.

The RHC should have written policies and procedures for determining what drug/biologicals are stored to provide such emergency services. The policy and procedures should also reflect the process for determining which drugs/biologicals to store, including who is responsible for making this determination.

They should be able to provide a complete list of which drugs/biologicals are stored and in what quantities. Since RHCs and federally qualified health centers (FQHCs) share the same regulatory requirements as it relates to emergency procedures under 42 CFR 491.9(c)(3), this revision will also apply to FQHCs.

Effective Date: Immediately.
This guidance should be communicated with all survey and certification staff, their managers and the State/Regional Office training coordinators within 30days of this memorandum.
Please let us know if you need help with your policies!