What replaced F758?
F605 replaced it. Since 28 April 2025, CMS surveys the unnecessary use of psychotropic medication under F605, the tag for the right to be free from chemical restraints, and F758 is no longer cited. Pharmacore checked this against CMS's current surveyor guidance (Appendix PP, Rev. 232) on 2 October 2026.
What CMS changed
CMS memo QSO-25-14-NH, dated 10 March 2025, states: “The regulations and guidance for the unnecessary use of psychotropics (F758) have been incorporated into F605. This change will help to streamline the survey process, increase consistency, and strengthen our message that facilities must prevent the unnecessary use of psychotropic medications.”
Appendix PP now carries a single line under F758: “Regulatory requirements for §483.45(c)(3), and §483.45(e) have been relocated to F605.”
Timeline
- 16 January 2025: CMS releases the revised surveyor guidance as QSO-25-12-NH.
- 10 March 2025: CMS reissues it as QSO-25-14-NH and moves implementation from 24 March to 28 April 2025.
- 28 April 2025: surveyors begin using the new guidance on surveys.
- 25 April to 23 July 2025: CMS updates Appendix PP. The F605, F756 and F757 text appears in Rev. 229 (issued 25 April 2025) and the F758 relocation note in Rev. 231 (issued 9 July 2025). Rev. 232 (issued 23 July 2025) is the current version Pharmacore checked.
Where each requirement sits now
| Requirement | Regulation | Tag since 28 April 2025 |
|---|---|---|
| Definition of a psychotropic drug | §483.45(c)(3) | F605 (was F758) |
| Psychotropic drugs: indication, gradual dose reduction, PRN limits | §483.45(e) | F605 (was F758) |
| Freedom from chemical restraints | §483.10(e)(1), §483.12(a)(2) | F605 |
| Unnecessary drugs, other than psychotropics | §483.45(d) | F757 |
| Monthly drug regimen review by a licensed pharmacist | §483.45(c)(1), (2), (4), (5) | F756 |
What is the difference between F757 and F605 now?
The split is by type of medication. The memo states that “Unnecessary Medications (F757) has been revised to only include guidance for non-psychotropic medications.” Appendix PP directs surveyors: “For concerns related to psychotropic medications only, including the unnecessary medication requirements, surveyors should assess compliance with §483.10(e), §483.12(a), and §§483.45(c) and (e), F605.” More detail is on the F757 page and the F605 page.
Two other changes in the same memo
- Convenience. The memo says guidance on “convenience” now includes “situations when medications are used to cause symptoms consistent with sedation and/or require less effort by facility staff to meet the resident’s needs.”
- Informed participation. The memo adds emphasis that “before initiating or increasing a psychotropic medication, the resident must be notified of and have the right to participate in their treatment, including the right to accept or decline the medication.”
What it means for the monthly review
The consultant pharmacist’s monthly drug regimen review is still required under F756. What changed is where surveyors place psychotropic findings: a concern about an unnecessary antipsychotic, a missed gradual dose reduction or an open-ended PRN psychotropic order is now considered under F605, not F758. Recommendations and irregularity reports that refer to F758 by name are worth updating.
Related reference pages
- F605: chemical restraints and psychotropic medication
- F756: the monthly medication regimen review
- F757: unnecessary drugs
- Consultant pharmacy glossary
Sources
- CMS, QSO-25-14-NH: Revised Long-Term Care Surveyor Guidance (revised 10 March 2025)
- CMS State Operations Manual, Appendix PP, Guidance to Surveyors for Long Term Care Facilities (Rev. 232)
- 42 CFR 483.45, Pharmacy services (eCFR)
Checked against these CMS sources on 2 October 2026. This page summarizes federal guidance for orientation. It is not legal or clinical advice; read the source documents and your state requirements before acting on it.
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