Historically, medical directors have had an indistinct role in the survey process. The survey process includes both the actual survey itself, and the elements of care that influence survey results. There are few specific federal requirements or F-tags that directly pertain to the survey-related required roles and responsibilities of medical directors. Three areas of the State Operations Manual (SOM) explicitly address the role of the medical director: Drug Regimen Review, Medical Director Presence, and Quality Assurance.
Drug Regimen Review, F429, notes that facilities are encouraged to share the pharmacists’ drug review with the medical director. Medical Director Presence, F501, states medical directors, retained by the facility, are responsible for implementing resident care policies and coordinating medical care in the facility. Quality Assurance, F520, notes that a medical director may be the physician designated by the facility to serve on the quality assurance committee.
Many clinically based Interpretative Guidelines associated with various F-tags imply the medical director’s oversight and responsibility roles, but are not clearly delineated as to extent, methods or authority. Anti-psychotic drugs (F331), unnecessary drugs (F329), hydration (F327), nutrition (F324), naso-gastric tubes (F321-22), urinary incontinence (F315), pressure sores (F314), and restraints (F221-27) are prominent sections of concern, yet have no specified role for medical directors in the survey process.
Note: Effective August 13, 2024, AMDA - The Society for Post-Acute and Long-Term Care Medicine is now Post-Acute and Long-Term Care Medical Association (PALTmed).