Lack of On-Site Medical Director Oversight and Contractual Structure
Penalty
Summary
The deficiency involves the facility’s failure to ensure provision and oversight of a Medical Director in accordance with federal requirements. Interviews and document review with the Administrator and DON showed the facility had no current physicians coming to the facility. The DON reported that the facility had one physician designated as the Medical Director, but this physician was not available to come to the facility and was only available by phone. During the prior year there had been a second physician, but that physician retired on an unknown date and was not replaced. All residents were patients either of the Medical Director, who was not available to come to the facility, or of Optum, which provided APRN coverage. The DON stated that weekly Medical Director rounds were supposed to occur every Thursday, but no physician conducted rounds on the most recent scheduled date and none was scheduled for the following week; the last documented rounds occurred 12 days before the survey interview. The Administrator confirmed there was no Medical Director available to come into the facility for weekly rounds. After the second physician retired, the Administrator contacted two physicians about coverage and then waited for the Medical Director to locate a second physician, without advertising or using a staffing agency to secure coverage. The facility was unable to demonstrate that the designated Medical Director provided routine, ongoing oversight within the facility, including at least weekly on-site presence. Record review did not identify a current, executed contract defining the Medical Director’s responsibilities, availability, and coverage expectations. The facility also lacked documentation of a contingency agreement or alternate coverage plan for Medical Director services if the appointed Medical Director was unavailable or failed to provide required services, and could not provide a policy outlining the Medical Director’s roles, responsibilities, and expectations for facility involvement and oversight.
