Alliance Public Comment: Stop Conflating Staffing Issues with Inappropriate Use of Antipsychotics

The following statement was made today by Alliance President and CEO Sue Peschin, MHS, during the public comment portion of the Advisory Council on Alzheimer’s Research, Care, and Services meeting on implementation of the National Alzheimer’s Project Act (NAPA). View a recording of the entire meeting, or a clip of the below statement.

My name is Sue Peschin and I serve as President and CEO of the Alliance for Aging Research. The Alliance supports CMS’s efforts to promote appropriate nursing home staff levels. However, given the ongoing long-term care hiring crisis, this seems like the right prescription at the wrong time.

Additionally, we are asking the agency to please stop conflating staffing issues with inappropriate use of antipsychotics. CMS needs to take immediate action to fix the agency’s outdated antipsychotic quality measure, which create incentives for misdiagnosis and prevent patient-centered care grounded in clinical standards.

The reality is that neuropsychiatric symptoms related to Alzheimer’s often require medical attention. Long-term care providers are trained to start with non-pharmacologic approaches. If these become ineffective, residents who would benefit from medical treatment deserve to have a federal policy that ensures access to FDA-approved options to help combat extreme agitation, delusions, and potential harm to the beneficiary, their family caregivers, and staff. Importantly, nursing home medical staff should be able to prescribe without fear of negative rating ramifications for their facilities.

The current metrics fail to capture data on crucial points, such as the number of residents who are involuntarily kicked out because facilities are directed against medically treating residents who are struggling. Extensive research work commissioned by ASPE in September of last year on nursing home-initiated involuntary discharges, found that behavioral symptoms and psychiatric and mood disorders are the most prominent risk factors for live discharge. So, we’re going to be a nation filled with homeless people living with dementia if these policies don’t change.

For the past three years, Project PAUSE member organizations—representing long-term care nurses, medical directors, pharmacists, geriatric psychiatrists, family caregivers, and older adults—have urged CMS officials to update these measures. We’ve reasonably asked them to require documentation of the “what, why and how” a medication is being prescribed. The agency has taken zero accountability, and our pleas have been ignored. 

The current staffing crisis in nursing homes will require a more timely and nuanced approach, in which CMS considers the real-world impact on patient access to appropriate care, the overall impact on nursing staff, and the real-world consequences of outdated metrics that have failed Medicare beneficiaries, families, and nursing home workers. Thank you.