Why Active Medical Director Engagement Protects Residents And Your Facility

We examine how CMS F841 and new OIG oversight raise expectations for nursing home medical directors, demanding visible engagement, better policies, and data-informed leadership. We share field lessons on antipsychotics, facility assessment, and building dashboards that support real accountability.

• CMS shifts from F501 to F841 and clarifies medical director duties
• OIG focus on engagement, visit frequency, and compensation integrity
• Risks of absent or passive medical directors in daily care
• Antipsychotics oversight, diagnostic accuracy, and documentation alignment
• Hands-on leadership beyond QAPI with nursing and administration
• Facility assessment that reflects the real resident mix and needs
• Data and AI dashboards to drive timely, targeted action
• Contracts, coverage, and accountability that sustain engagement

Please feel free to reach out to Verity Consulting at VerityTeam.com if you'd like further assistance with your healthcare compliance needs

Chapters

• 0:19 Host Introduction And Disclaimer
• 0:56 Framing The Topic: Role Of Medical Director
• 3:20 CMS Updates: From F501 To F841
• 4:56 OIG Focus On Engagement And Fraud Risks
• 8:16 2025–2026 Oversight: Monitoring Engagement
• 11:30 Practical Realities And Turnover Challenges
• 15:20 Required Duties: Policy, Visits, And Availability
• 19:20 Antipsychotics, Diagnoses, And Documentation

Transcript

SPEAKER_01: 0:19

Hello, I will be your host. My name is Deanna Fi. I am a registered nurse and healthcare analyst. Let's get started.

SPEAKER_00: 0:30

The views or opinions expressed in this podcast are for informational purposes only, not intended as legal or professional advice, and may not represent those of Verity Consulting. Although we make strong efforts to make sure our information is accurate at the time the podcast episode was recorded, Verity Consulting cannot guarantee that all information in this podcast is always correct, complete, or up to date. All information in this podcast is subject to change without notice.

SPEAKER_01: 0:56

Welcome to Vital Compliance Insights. Today we will tackle the role of the medical director in those long-term care facilities that participate in Medicare and Medicaid funding. So what I want to do is come at this from a couple different angles. First of all, I am a registered nurse, so in my long career, I have worked with many, many physicians, medical directors of facilities, and also corporate level medical directors. And in the capacity that I've conducted CMS federal surveys, I've worked with those individuals as well. And as an external monitor for the OIG conducting corporate integrity agreements. So I'm going to kind of flavor this discussion today with a few of those experiences that I've had and try to focus on what I think are really important points that'll hopefully help the facility be successful. And I always say it at the end, but at any time, if your organization, whether large or small, needs any kind of assistance, Verity Team, it's a great team of professionals, can help assist with some needs you may have. Okay, so let's dig in. So anyone who works in this industry, long-term care facilities, are very familiar with the CMS requirements where when you're accepting Medicare and Medicaid monies, you must have a qualified medical director. And that individual must be responsible for obviously the coordination of medical care. So this person is the captain of the ship saying, hey, here are the things that I think are important to care for our residents here. They should be the person setting the standards of care practices for clinical care. And it should really be this person should be a leader, not only a clinical leader, but a leader among the facility staff to move the facility forward. So we we kind of that's not new. I mean, we're going back to, oh gee, 2005, uh CMS had come out with some guidance. Well, things have changed a little bit. So when I say changed, there have been some changes in 2025 that came out. CMS Transmital 231 came out with some guidance that said, hey, we're changing the federal tag from F501 to F 841. So they made some changes. And so in the surveyor guidance, the, you know, the very guidance that surveyors are going to use to evaluate the effectiveness of the medical director role, there's some further clarification of the responsibilities. And we'll get to that in a little bit. I want to kind of cross-reference not only what CMS is saying, they're requiring of a medical director, but and I say requiring, these are some of the elements that the CMS has indicated are essential to ensure a safe quality resident care. Now I want to crosswalk back with the Office of Inspector General guidance. So as you know or may not know, the OIG has really made it pretty clear in their multiple communications over the years that the medical director role is a is a very important leadership role in the facility, much like CMS has said. Now, things are changing just a little bit here with the OIG. Of course, they're looking at fraud, they're looking at those kinds of things, you know, billing issues and all that. So that's not anything that CMS is really concerned about, but the OIG has been really watching that in facilities for years. So in 2023, though, the OIG came out with a report, and they said, look, we're gonna we're gonna evaluate the frequency of visits to to the long-term care facility. You know, how often are they coming to the facility to do the work? How what's the amount of time they're spending? And certainly they're also concerned about is there even a medical director assigned to this facility? So we know there are medical directors that can fill in temporarily while there are some transitions. Certainly we know you know the medical director role, or I know as a nurse, the medical director role is a very challenging role. And some physicians aren't really totally prepared to go from clinical resident care to leadership. So there can be turnover in that role. But the OIG is saying we're gonna pay attention to how often the medical director is in the facility, and they're certainly going to be looking at payroll, how they're paid. All right, but I don't want to get off into that too much. So while the CMS on the one side is saying we really want to make sure this person, the medical director, is engaged, actively involved, the OIG is saying the same thing. They're just gonna come at it from a little bit different angle. So the OIG in 2024 came out with industry-specific compliance program guidance for nursing facilities. Okay, and if you haven't read that, you need to look that up and really get well acquainted with that. And they're saying that you must obviously have a physician that's designated to serve as the medical director. And this person is responsible for coordinating care. And there's certainly a lot more illustration of what they mean by that. So, all right, let's let's bring us to 2025. What's going on? Well, CMS is saying, okay, we have F 841, that's the guidance for medical director responsibilities, which I already discussed. But OIG is also saying in 2025, June, they are concerned with the level of engagement of the medical director in a nursing facility. And it's not all that different than what CMS is saying as well. Again, they're looking at is the work being done? Is are they fulfilling their required duties? Okay. And so they published a document in June 2025, the OIG, titled Monitoring Nursing Home Engagement of the Medical Directors. So you can look that up. Mike might post that as a blog as well on the Verity Team website. And their guidance isn't due to be implemented until 2026. So there's no further clarification on when in 2026. But the OIG said, again, we're looking at level of engagement by a medical director in a nursing facility. You know, there's going to be a couple different elements there. The work demands. Uh, resident care. Some resident care certainly requires a lot more monitoring. And is that being done? And the medical director is really an important person to say uh the medical director may not be the attending physician. It may be a different physician managing a resident with some complex care needs. But the medical director needs to know who who those residents are in the facility. And it would be appropriate to say, hey, how's how's it going? How's this person being managed? Any concerns, any issues? One thing I'll underscore, and I agree with, the OIG and the CMS are saying the same thing. There needs to be active involvement. And I'll sprinkle a couple of comments in there from my past experiences. The medical director may need some additional training on some changes, whatever those might be in the facility. And there are many, we know things are in healthcare are evolving so rapidly. So let me just sprinkle a couple comments in there. When I conducted the corporate integrity agreement monitoring for OIG, I of course would always ask, is there a medical director? The answer should be yes, but is there one? Okay. Is this individual available where I could interview the individual? And there were many times when the answer was no, there is not one. No, we really don't have a backup plan, or we do have a backup plan, but it's grossly insufficient. So there were many opportunities where I would talk to administration, director of nursing, and say, you know, who is helping guide, I would ask rather, who is helping to guide the standards of care here in this facility? And there were times when they said, well, we're using the corporate medical director. And I'd say, okay, so you have someone in that role, but are they actively involved? How can they be? How's this working? So, you know, we can peel the onion layer by layer here to find out, are people, medical directors, really involved? And realizing, let's be, let's be honest, it's difficult to find medical physicians willing to be medical directors. And it's it's another duty they're adding to maybe managing resident care load of assigned residents. So doing that plus being in an administrative role can be really challenging. But if this person agrees to do that and is willing to take the money for that, then they really need to be available and actively involved. We we know that. So that puts the onus on the facility, the corporation to hold their feet to the fire to say, come on, you have to do this. But let's be real and realistic here. It's difficult with so much happening. So this is where I just wanted to talk a little bit about the CMS is asking for, and they're really making this very clear. Is the medical director active in the development and implementation of resident care policies? Okay. And this is a good time to really emphasize this point, I hope, because the CMS has made it pretty clear, and as has OIG, the use of, I'll say broadly, psychopharmacologic medications, but in particular, antipsychotic medications. They've made it really clear that CMS has said to their surveyors, hey, listen, when you're out there, you need to look and find, you know, are residents assigned psychiatric diagnoses? What are those diagnoses? Are the medications appropriate? So and is there supporting documentation to say this person does have that diagnosis based on the most recent diagnostic manual? So I would definitely say that this is a time when the medical director really needs to sharpen the pencil, so to speak, and make sure they are actively involved in developing policies and guidelines to help residents with particularly psychiatric diagnoses or and the use of antipsychotic medications. This will be under the magnifying glass. I will say that this medical director has to be actively involved. And I'm not talking just about the, you know, the quality assurance performance improv performance improvement meetings facilities have. I'm not saying show up and be on the roster and talk about what the latest quality indicators are and such, but to be actively involved, have an active ongoing dialogue with the director of nursing in the facility and with the administrators to talk about what's happening with the resident care. Are other providers doing their job? And so how can I help to facilitate that? So at the end of the day, this message has been very clear. CMS and OIG are asking active engagement, participation in the overall resident care program. So with that, I will say this is a good time for facilities if you haven't done it, is to really develop good systems. And there are so many organizations out there that can help give guidance on developing good systems of communication. And you and I know everyone is aware we're in the advent of the whole AI, all the AI effects that we're going to see now. But those can be good things. There can be good that can come out of this. There's going to be a lot of data analytics that AI can help with. And I know physicians well enough to know they they want data in front of them, they want good quality data in front of them so they can look at it, perform an assessment, and then go forth and make recommendations. So, how can we help the medical director to be effective? So this is a good time to say, all right, we we're going to work together to come up with the data you need to present a profile of what's required. But I do want to underscore the medical director must be involved in the facility assessment. And I know there's a lot of discussion about that in the CMS guidance. But if you really think about it, at any given time, a medical director should be able to say this facility has this kind of resident population, whatever it is you want to describe, all the demographics, okay? You know, 75% female, you know, we have 10% of our resident population has another language, non-English. So the the you need to really, that physician, medical director has to have a good grasp of my population, who is in my facility, okay? Because then that gives you a clearer idea on what are the care needs. Are we touching upon or do we have the right people involved in managing the care? Because if you have a a large concentration percentage rather of residents who have complex psychiatric diagnoses with symptoms of distress behavior, do we have the right people in our physician or provider list to help manage them effectively? Okay. So technology data can help, but you need a really good baseline profile. And I really think that'll help the medical director to say, okay, where can we triage, where can we put more focus on which areas? Okay. Creating a nice dashboard of data with the medical director would be so helpful to help the medical director to be as effective as possible, particularly the medical director that's trying to manage a patient resident care load. And that way everybody wins. You're making it a little easier for me to be actively involved and participate. I'm very, very busy juggling a lot of other balls, but together we can create a good system. So I think that's what I think there this can be done. And I don't think people should be so worried. The medical director is is an important role. I know as a nurse, we need medical directors to provide, or physicians to provide guidance on which direction we should take. Something's not working. What else can we do? Okay. So I just wanted to say I I haven't experienced just an overall absence of a medical director. That's one thing. But to have a medical director on record, but who's still absent, might show up at a meeting, but just doesn't say anything. So we definitely are going to be looking for medical directors who are actively involved and asking all the right questions about who who are my residents? Are we following the latest standards of care? If there's some if there's if it's unclear, we need to get the right people involved. Okay. But again, the medical director really is the captain of the ship as far as the clinical care. And this medical director has to be willing and ready to speak to other providers to say, hey, wait a minute, your practices are not in alignment with our policies and procedures. So that will definitely be important and be looked at. So the buck is going to stop with the medical director. So do I think this can be done? Of course. It's been done in facilities for decades very well. In fact, in my past roles, I've seen where some facilities that were under corporate integrity agreement requirements actually finished early, if you will. They actually, in their five-year agreement with the OIG, finished early. They met their requirements and they really pulled everything together. And when you look at that facility that did that, for an example, they had strong leadership, clinical leadership from a strong, actively involved medical director. So it goes without saying. So with that, I'm going to wrap up a little bit here to say I believe facilities are going to be at a turning point and they can harvest all the good data, work with a medical director to say, what do we need to help make it easier for you, doctor? And this is what we need from you. And administration is going to really have to hold their feet to the fire for those individuals that are going to need that. Okay. So a lot of positive things. If at any time you need any assistance from Verity Team, group of consultants, they are available to you. So please reach out. I hope this episode was helpful. Have a good day. Thank you for listening. Your time is appreciated. We hope you enjoyed this episode of Vital Compliance Insights and found this to be informative. Please feel free to reach out to Verity Consulting at VerityTeam.com if you'd like further assistance with your healthcare compliance needs. Stay tuned for the next episode.