CMS SOM App. H, Tag V549

address, but not be limited to, the following: (4) Anemia. …The patient’s response to

erythropoiesis-stimulating agent(s), including blood pressure levels and utilization of iron

stores, must be monitored on a routine basis.

Interpretive Guidance § 494.90(a)(4)

Note: this guidance is a continuation of the regulatory requirement at § 494.90(a)(4).

The facility must monitor patients’ blood pressure levels and take action upon significant

abnormalities for each patient. Hypertension may have many causes; failure to develop and

implement a plan to control high blood pressure should be cited at V543.

Measurements of patients’ iron stores include serum ferritin and transferrin saturation. The

facility must establish targets for iron management that reflect professionally accepted clinical

practice standards.

If the IDT chooses to use medication algorithms or protocols for anemia/iron management, the

care for each patient must be individualized. The physician or a non-physician practitioner (i.e.,

an advanced practice registered nurse or a physician assistant) is responsible for ordering

medications and laboratory tests and may or may not use standing orders or an algorithm.

The IDT must develop a program for anemia and iron management, and monitor laboratory

results, orders for intravenous iron preparations, and medication administration records to

address values outside the target levels. Laboratory values outside the target levels must be

addressed; doses adjusted as necessary; and medications administered as ordered.

If there is a trend of problems in iron management for an individual patient, the IDT must

develop an outcome-oriented plan based on their assessment of the problem and identification of

possible barriers to attaining the goals.

The requirements for patient assessment of anemia/iron are at V507 and for blood pressure/fluid

management at V504.