F-tag 501 medical director: where are we now?

It has been almost 4 years since the revised F-tag 501 medical director was released by the Centers for Medicare and Medicaid Services (CMS). There was much consternation at that time regarding the impact it would have on the future of long-term care and medical director–facility relationship. Much has been written on what the medical director should be doing given the new regulations. The question remains, is it being done, and does anybody know if it is? The mandatory presence of a medical director in nursing facilities came about in the 1980s, after the congressionalcommissioned Institute of Medicine report detailed the need for widespread reform of nursing home regulations. Most of these were incorporated into the Omnibus Budget Reconciliation Act of 1987 (OBRA-87), including Tag F501, Medical Director. The regulation itself, CFR 483.75(i), notes the medical director was responsible only for the implementation of medical care policies and the coordination of medical care in the facility, without much further elaboration under the original guidance to surveyors or investigative protocols. Words in such documents such as ‘‘appropriate care,’’ ‘‘significant role,’’ and ‘‘appropriate steps’’ were relatively broad and vague. Before 2005, there were no investigative protocols and no formal methods for surveyors to determine true compliance. Pragmatic changes were necessary to allow the medical director to perform basic functions with authority. Interdisciplinary cooperation must occur for the medical director to achieve his or her goals, as quality assurance cannot occur with the effort of a single individual. The medical director must determine the educational needs of the staff, establish protocols for medication and practitioner monitoring, and promote accountability, teamwork, and quality of care. The medical director in brief should be a troubleshooter, patient advocate, and technical advisor. The revised interpretive guidance now has clearly spelled out expectations of medical directors in much more detail. Perhaps the key aspect was that citation for F501 can be cited only with the context of other federal tags. That is, there must be a deficiency in a quality-of-care issue, such as pressure ulcers, medications, or hydration for the medical director to be found deficient in his or her practice. Interestingly, there are