Documenting the Cost of Medical Director Time Spent

It should be noted however, in the final rule, that CMS referenced several different ways for a medical director to accomplish training goals for clinical staff such as using pre-packaged training programs. Clearly a pre-packaged program is less time consuming from the point of view of a medical director. So CMS has tacitly left the door open to accomplishing goals in a variety of ways—some of which take more direct medical director time and some less.

So the question remains, how seriously should a facility take the time commitment benchmark of 0.25 FTE? My thoughts are that there will be much more scrutiny of time spent by a medical director in those areas where deficiencies are identified. For instance, consider a deficiency in water treatment—would it look good to have no or very little documented medical director time spent on this area of responsibility?

It would seem much wiser to primarily focus on accomplishing the CfCs implementation while also tracking, in a reasonable fashion, the ongoing time spent by the medical director in requirements such as interdisciplinary meetings.

Clearly, there is no specific mandate for documenting medical director time. However, one might ask, without documentation of time spent how a facility would defend against claims of inadequate medical director time, especially in any area of deficiency?

I suggest a simple, spreadsheet-based time log that would capture most major tasks, but not detail every single minute of the medical director’s time. The log could be reviewed and signed by the medical director on a weekly basis and should capture time under the same headings used for the CfCs.