Preventing Errors Relating to Commonly Used Anticoagulants
September 18, 2008

Applicable Joint Commission Standards

National Patient Safety Goal 3E
Anticoagulation Therapy

Requirement 3E
Reduce the likelihood of patient harm associated with the use of anticoagulation therapy.

Note: This requirement applies only to organizations that provide anticoagulation therapy.

Rationale for Requirement 3E
Anticoagulation is a high risk treatment, which commonly leads to adverse drug events due to the complexity of dosing these medications, monitoring their effects, and ensuring patient compliance with outpatient therapy. The use of standardized practices that include patient involvement can reduce the risk of adverse drug events associated with the use of heparin (unfractionated), low molecular weight heparin (LMWH), warfarin, and other anticoagulants.

Note: This requirement has a one-year phase-in period that includes defined expectations for planning, development, and testing (“milestones”) at three, six, and nine months in 2008, with the expectation of full implementation by January 1, 2009.

  1.  As of April 1, 2008, the organization’s leadership has assigned responsibility for oversight and coordination of the development, testing, and implementation of Requirement 3E.
  2.  As of July 1, 2008, an implementation work plan is in place that identifies adequate resources, assigned accountabilities, and a time line for full implementation of Requirement 3E by January 1, 2009.
  3. As of October 1, 2008, pilot testing in at least one clinical unit is under way.
  4. As of January 1, 2009, the process is fully implemented across the organization.

The Implementation Expectations that will apply beginning January 1, 2009, are provided below.

Implementation Expectations for Requirement 3E

  1. The organization implements a defined anticoagulant management program to individualize the care provided to each patient receiving anticoagulant therapy.
  2. To reduce compounding and labeling errors, the organization uses ONLY oral unit dose products and pre-mixed infusions, when these products are available.
  3. When pharmacy services are provided by the organization, warfarin is dispensed for each patient in accordance with established monitoring procedures.
  4. The organization uses approved protocols for the initiation and maintenance of anticoagulation therapy appropriate to the medication used, to the condition being treated, and to the potential for drug interactions.
  5. For patients being started on warfarin, a baseline International Normalized Ratio (INR) is available, and for all patients receiving warfarin therapy, a current INR is available and is used to monitor and adjust therapy.
  6. When dietary services are provided by the organization, the service is notified of all patients receiving warfarin and responds according to its established food/drug interaction program.
  7. When heparin is administered intravenously and continuously, the organization uses programmable infusion pumps.
  8. The organization has a policy that addresses baseline and ongoing laboratories tests that are required for heparin and low molecular weight heparin therapies.


National Patient Safety Goal 8
Accurately and completely reconcile medications across the continuum of care.

Requirement 8A
There is a process for comparing the patient’s current medications with those ordered for the patient while under the care of the organization.

Rationale for Requirement 8A
Patients are most at risk during transitions in care (hand-offs) across settings, services, providers, or levels of care. The development, reconciliation and communication of an accurate medication list throughout the continuum of care is essential in the reduction of transition-related adverse drug events.

Implementation Expectations for Requirement 8A

  1. The organization, with the patient’s involvement, creates a complete list of the patient’s current medications at admission/entry.
  2. The medications ordered for, administered to, or dispensed to the patient while under the care of the organization are compared to those on the list and any discrepancies (e.g., omissions, duplications, potential interactions) are resolved.

Requirement 8B
A complete list of the patient’s medications is communicated to the next provider of service when a patient is referred or transferred to another setting, service, practitioner or level of care within or outside the organization. The complete list of medications is also provided to the patient on discharge from the organization.

Implementation Expectations for Requirement 8B

  1. The patient’s accurate medication reconciliation list (complete with medications prescribed by the first provider of service) is communicated to the next provider of service, whether it be within or outside the organization.
  2. The next provider of service checks the medication reconciliation list again to make sure it is accurate and in concert with any new medications to be ordered/prescribed.
  3. The complete list of medications is also provided to the patient on discharge from the organization.


Standard MM.7.10
The hospital develops processes for managing high-risk or high-alert medications.

Elements of Performance for MM.7.10

  1. The hospital identifies the high-risk or high-alert medications used within the hospital, if any.
  2. Based on the services provided, the hospital develops processes for procuring, storing, ordering, transcribing, preparing, dispensing, administering, and/or monitoring high-risk or high-alert medications.
  3. The processes for managing high-risk or high-alert medications are implemented.