Ok, the Holidays are over, the election is long over, and it is time we get back to business. As noted last month, I will provide some insight on how to document the time spent by medical directors for CfC and cost report purposes.
As I researched this article I found 123 references to the medical director in the Conditions for Coverage final rule and 104 references in the Interpretive Guidelines. Clearly a lot of new regulatory guidance has been injected into defining and assessing the role of the medical director.
The Interpretive Guidelines provide substantial detail regarding the specific responsibilities of the medical director. Moreover, the CfC Interpretive Guidelines specify CMS expectations with respect to the time that these responsibilities will require on the part of the medial director:
“The medical director should devote sufficient time to fulfilling these responsibilities. As a guideline, the financial cost report each facility must file annually with CMS considers the medical director positions to reflect a 0.25 FTE.”
For those of you who may not commonly work with salary-related calculations, the 0.25 FTE reference may seem somewhat nebulous. An FTE, or Full Time Equivalent, is commonly accepted to be 2,080 hours per year, so 0.25 FTE means 520 hours/year, which is about 43 hours a month or 10 hours a week. So if you cannot document the equivalent of 10 hours of medical director involvement per week, you will probably fall short of the 0.25 FTE guideline. But keep in mind that 0.25 FTE is a guideline, and that the operative phrase is “sufficient time.”
It is important to recognize that the 0.25 FTE guideline, as taken from cost reporting standards, has subtle but real ramifications. CMS is stating in a measurable way the time commitment expected from one person, the medical director. The 0.25 FTE is not a mandated minimum time requirement; however it is a numeric benchmark and benchmarks tend to eventually be used in assessing performance. Keeping in mind that there can only be one medical director per facility, it becomes clear that there is probably not an immensity of wiggle room should a facility fall short. There is only one medical director, and the time commitment guideline is 10 hours per week, so clearly this one person is expected to put in “sufficient time,” which would be expected to fall in the range of an average of 10 hours a week.