This week’s “Ftag of the Week” on the CMSCG Blog is F841 Responsibilities of Medical Director, which is part of the Administration regulatory group. The regulation requires that each nursing facility has designates a physician who will act as the Medical Director. The Medical Director is responsible for implementation of resident care policies and coordination of medical care in the nursing home.
As we mentioned in our last Ftag of the Week post which provided a review of F868 QAA Committee, the Interpretive Guidance related to the Medical Director and his/her responsibilities has been greatly expanded under the RoPs, including under this week’s Ftag F841. The IG states that facilities are responsible for identifying how the Medical Director will fulfill his/her responsibilities outlined in the regulation related to effectively implementing resident care policies and coordinating medical care for the facility’s residents. This can be part of the job description or through a policy.
Medical Director Responsibilities
The Medical Director’s responsibilities require that the Medical Director:
- Knows current standards of practice related to the care of LTC residents and how to oversee other practitioners. He/she should also assist with developing staff education.
- Participates in administrative decisions related to resident care policies, including developing, recommending and approving these policies.
- Participates on the QAA Committee (or assigns a designee) and through other activities addresses issues related to medical care coordination in the facility.
- Participates in organizing and coordinating the services provided by physicians and other professionals. He/she must also identify performance expectations for physicians as well as facilitating feedback based on performance and practices. If a health care practitioner is providing care inconsistent with current standards of care, the Medical Director should discuss and intervene if necessary.
- Is responsible for the quality of medical/medically-related care being provided.
- Is expected to work with the facility’s clinical staff on developing policies to prevent potential infections as well as surveillance activities.
- Promotes person-centered care, including through the formation of advance directives protocols and promoting resident choice in making care decisions.
- Assists with developing performance monitoring systems to resolve issues related to medical care.
Other Important Points
- If the Medical Director is also an attending physician, the facility needs to ensure that there is a mechanism to ensure there are no concerns/issues with his/her performance, so the Medical Director is not reviewing his/her own performance.
- If a facility is part of a multi-facility organization and the Medical Director is involved in developing corporate/regional policies, the policies in place for each facility must be facility-specific based on the facility’s residents’ needs and environment.
- If the Medical Director names a designee to participate on the QAA Committee, his/her responsibility as a member of the Committee is not changed, nor is his/her responsibility for overseeing overall medical care within a facility.
If a resident care-related deficiency is identified on survey, surveyors are expected to determine if the Medical Director was aware of (or should have been) a problem with care, physician services, or if care policies and practices were not in place or not reflective of current standards of practice. The IG also asks surveyors to identify if the Medical Director failed to get involved in facilitating/coordinating care or interceding with other practitioners in care delivery when a concern is identified, or if he/she failed to provide guidance related to resident care policies.
It is time to pull out your Medical Director’s job description and review it to ensure that it is current and reflects regulatory compliance. If you have not taken the time to meet with the Medical Director to discuss his/her duties and responsibilities, this is a good time to do so. The Medical Director should be a key player in developing resident care policies, and providing this practitioner with a copy of F841 should help him/her get that message.