March 27, 2025
McKnight's Long-Term Care News
Updates to Center of Medicare & Medicaid Services nursing home surveyor guidance will enable medical directors to lead the charge in preparing facilities to comply with key competencies.
The guidance, which goes into effect April 28, highlights CMS intentions to have surveyors evaluate the evolving role of the medical director, said Susan Levy, MD, medical director and consultant at SML Geriatric Medicine Consulting. She was one of several speakers who discussed the new guidance at the PALTC25 conference for post-acute and long-term care medical providers earlier this month.
Regulators placing more responsibility in the hands of medical directors is welcomed, said host Timothy Holahan, DO, assistant professor of medicine at the University of Rochester. But changes will require medical directors to get more involved in a range of issues, including most notably prescribing and diagnoses of behavioral health conditions.
“[This] is something we’ve been fighting for,” Holahan said. “It can seem a little daunting at first, but I do think we have to take this as a positive sign that CMS and other organizations see the value that we provide.”
Vicki Walker, medical director and clinical officer at Avel eCare Senior Care, provided examples of how medical directors can better assert themselves when determining the accuracy of schizophrenia diagnoses or the use of drugs to control certain behaviors. CMS has over the last several years increased scrutiny of such diagnoses, culminating in widespread audits and now more detailed requirements for medical directors.
“I think this guidance is really saying [medical directors] have a responsibility to actually talk to prescribers about what they’re prescribing,” Levy said. “You have a responsibility to talk to the attending physician about the diagnosis that’s on the chart. You’re going to have a conversation with that person and set clear expectations about what best practice looks like and what the expectations are.”
Shifting the mindset
But medical directors shouldn’t task themselves with going it alone, Levy assured. They’ll want to lean on other members of the leadership team to assist with change implementation and compliance.
It’s about shifting one’s mindset from being reactive to proactive, she said.
“We often get a problem after we’ve already had a bad outcome. That’s what tends to happen, and then we try to fix it,” Levy said. “We’re trying to flip that so that we are more integrated into the leadership team than we are now. It’s a proactive role, and we’re going to try to help fix these things before they happen, which is really the intent of even having us in the building.”
Before closing, Holahan posed a question: How do medical directors take accountability and take action when the standard of care is not met?
“Start with making sure your medical staff has the education and the tools to do the right thing. Then sometimes, you have to start the difficult conversation of showing them data,” Levy explained.
“[Show them] here’s how you’re performing versus someone else or versus the national average, or [tell them] you’re not giving me good explanations for this and here’s where your documentation problems are. It may need to escalate in serious issues to a point where somebody doesn’t work in your building anymore.”
