How Mock Surveys Can Help Identify Overuse of Antipsychotics in Nursing Homes

Antipsychotic medications are frequently prescribed in nursing homes, often to manage behavioral symptoms of dementia. However, inappropriate use of these medications can lead to serious health risks for residents, including increased mortality, sedation, falls, and regulatory penalties.

To ensure compliance with Centers for Medicare & Medicaid Services (CMS) regulations, nursing homes must carefully monitor their antipsychotic prescribing practices. One of the best ways to proactively address medication management and compliance risks is through mock surveys—internal audits that mimic official state or federal inspections.Mock surveys allow facilities to:

• Identify gaps in compliance before official CMS surveys
• Detect inappropriate medication use and address it proactively
• Train staff on best practices for non-pharmacological interventions
• Improve CMS Five-Star Ratings and avoid penalties

The Importance of Identifying Antipsychotic Overuse in Nursing Homes

CMS has placed strict guidelines on antipsychotic use in nursing homes due to serious risks associated with these medications. Facilities that fail to meet federal and state requirements can face:

• F-Tag 758 deficiencies (Failure to prevent unnecessary psychotropic medication use)
• Financial penalties for non-compliance
• Negative impacts on Five-Star Ratings due to high antipsychotic prescribing rates
• Legal and ethical concerns from families and regulatory bodies

Mock surveys provide a proactive approach to evaluating antipsychotic prescribing patterns, ensuring that medications are only used when clinically appropriate and that non-pharmacological alternatives are prioritized.

Learn about Our Consulting Services

Key Areas Mock Surveys Should Assess

Reviewing Antipsychotic Prescribing Trends

A key aspect of a mock survey is analyzing the facility’s antipsychotic prescribing patterns to determine whether medications are being used appropriately and in compliance with CMS guidelines.

• Percentage of residents prescribed antipsychotics
• Comparisons to state and national benchmarks
• Documentation of clinical justification for medication use
• Evidence of non-drug interventions attempted before prescribing

Best Practice: Facilities should aim to keep antipsychotic prescribing rates below CMS’s national benchmark and have clear documentation supporting medication use.

Ensuring Compliance with F-Tag 758

CMS’s F-Tag 758 requires that nursing home residents be free from unnecessary psychotropic medications, including antipsychotics, unless clinically justified.

During a mock survey, assess the following:

• Was informed consent obtained before prescribing an antipsychotic?
• Are there proper diagnoses documented for all antipsychotic prescriptions?
• Have non-pharmacological interventions been attempted first?
• Has a gradual dose reduction (GDR) been attempted per CMS requirements?
• Are behavioral symptoms documented before and after medication use?

Best Practice: Ensure proper documentation of informed consent and non-drug interventions before prescribing antipsychotics.

Evaluating Gradual Dose Reduction (GDR) Compliance

CMS requires nursing homes to attempt Gradual Dose Reduction (GDR) for residents on antipsychotics unless clinically contraindicated.

Mock surveys should verify:

• GDR attempts are made at least twice in the first year
• Ongoing GDR attempts occur annually thereafter
• Clear documentation exists if GDR is deemed inappropriate

Best Practice: If a resident remains on an antipsychotic, ensure that the physician has documented clear reasons why GDR is not recommended.

Assessing Non-Pharmacological Approaches to Behavior Management

Before prescribing an antipsychotic, nursing homes must demonstrate that non-drug interventions were attempted and document their effectiveness.

Mock surveys should evaluate whether staff are:

• Using de-escalation techniques before considering medication
• Engaging residents in person-centered activities
• Identifying and addressing root causes of behavioral symptoms (e.g., pain, hunger, loneliness, environmental factors)
• Providing individualized care plans for managing behaviors without medications

Best Practice: Train staff to document all non-drug interventions attempted before prescribing an antipsychotic and track their effectiveness.

Interviewing Staff on Medication Use and Behavior Management

Mock surveyors should interview staff to assess their knowledge of antipsychotic use, non-drug interventions, and compliance requirements.

Sample staff interview questions:

• “How do you handle a resident experiencing agitation or aggression?”
• “What non-drug strategies do you use before requesting an antipsychotic?”
• “What is the process for obtaining informed consent before prescribing?”
• “How do you monitor and document the effectiveness of a resident’s medication?”

Best Practice: If staff struggle to answer these questions, additional training may be needed before an official CMS survey.

Checking Documentation for Compliance Readiness

Surveyors scrutinize medical records, so facilities should conduct regular audits of resident documentation.

Mock survey reviewers should check for:

• Clearly documented clinical justification for antipsychotic use
• Evidence of non-drug interventions attempted first
• Signed informed consent forms
• Regular physician reviews and GDR attempts
• Behavior monitoring records before and after medication changes

Best Practice: Maintain thorough, up-to-date documentation to avoid deficiencies during CMS inspections.

Book a Free Consultation

How Qsource Helps Nursing Homes with Mock Surveys

Qsource, skilled-nursing facility consultants, provides mock survey services to help nursing homes identify and correct compliance risks before CMS inspections.

Qsource Mock Survey Support Includes:

• Comprehensive medication audits to detect inappropriate prescribing
• Staff training on behavior management and survey readiness
• Guidance on improving documentation and compliance
• Personalized action plans for reducing antipsychotic use
• Regulatory updates and compliance coaching

Mock surveys are an essential tool for nursing homes to ensure compliance with antipsychotic regulations and improve resident safety and quality of care. By proactively identifying risks, strengthening staff training, and prioritizing non-drug interventions, facilities can reduce antipsychotic overuse and avoid CMS penalties.