Medical directors are central to the clinical integrity of skilled nursing facilities—but how involved are they, really?
While federal regulations outline specific responsibilities, there’s growing concern that the roles of medical directors are inconsistently defined, poorly documented, or limited in practice. In response, the U.S. Department of Health and Human Services (HHS), through its Office of Evaluation and Inspections (OEI), has launched a federal review to assess how medical directors are engaged—and how that engagement is tracked and verified.
Announced under OEI Report #OEI-07-25-00130 and expected in 2026, this review reflects a broader shift toward data-driven oversight and more meaningful clinical leadership in long-term care.
What the Federal Evaluation Will Examine
The OEI is evaluating three critical areas:
- Medical Director Responsibilities: Are they consistently fulfilling duties required by regulation and contract?
- Payroll-Based Journal (PBJ) Reporting Accuracy: Do submitted hours reflect actual time and involvement?
- Opportunities for Improved Oversight: Can new tools or data sources enhance accountability and transparency?
Why It Matters
PBJ data is currently one of the few available metrics of leadership engagement in skilled nursing facilities (SNFs), but it offers a limited view. The federal review may result in:
- Heightened scrutiny of PBJ data.
- Stronger compliance benchmarks for medical director contracts.
- Greater demand for evidence of real, ongoing leadership contributions.
- Improved care for seniors.
Facilities may soon need to demonstrate not only technical compliance but also meaningful clinical participation from their medical directors.
Proactive Steps for Providers
Now is the time to strengthen your medical leadership infrastructure. Steps to take include:
- Revisit Contracts: Ensure expectations align with the Centers for Medicare & Medicaid Services (CMS) guidelines and include clear responsibilities.
- Verifying PBJ Data: Compare reported hours to actual logs and activities.
- Integrate Medical Directors into Quality Assurance and Performance Improvement (QAPI): Include Medical Directors in planning, clinical policy review, and survey readiness efforts.
- Document Engagement Beyond Hours: Capture evidence of staff education, consultations, and leadership in care decisions.
If you need support assessing your current approach or preparing for regulatory review, LW Consulting, Inc. (LWCI) is here to help! For more information, contact LWCI to connect with one of our experts!
