Centers for Medicare & Medicaid Services (CMS)

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Join with AMDA and CMS in the nationwide effort to reduce the unnecessary use of antipsychotic agents by refocusing the interdisciplinary team on a better understanding of the root cause of dementia related behaviors. Click here to read a special message from AMDA Past- President Matthew S. Wayne, MD, CMD, on antipsychotics use in nursing homes.

The Centers for Medicare & Medicaid Services (CMS) is giving nursing home providers the opportunity to participate in a bold, new quality improvement initiative mandated through the Affordable Care Act. The Affordable Care Act requires CMS to “establish standards relating to Quality Assurance and Performance Improvement” (QAPI) and “provide technical assistance (TA) to facilities on the development of best practices” for QAPI. Click here to learn more.

AMDA has partnered with four states chapters (Minnesota, Illinois, Wisconsin, Michigan) to offer recommendations on the draft local coverage determination (LCD) covering physician evaluation and management services provided in the home and domiciliary setting (PHYS-081). Wisconsin Physician Services (WPS), which serves as the Medicare Part B carrier for the four states, issued the draft LCD drawing attention and criticism from AMDA members. Subsequently, the four state chapters sent a letter to Dr. Boren offering specific revisions to the draft LCD.

Edward Ratner, MD, President Minnesota Medical Directors Association says “Medicare Part B carriers should treat the medical house call, as a Medicare covered service, the same as similar services for similar patient in other settings. Carriers should require no additional documentation or justification for care of a frail beneficiary at home than would be needed to see such a patient in the office or nursing home.”

AMDA also has worked with the American College of Physicians (ACP) and the American Geriatric Society (AGS) to identify concerns with the draft LCD. The three national associations wrote to the Wisconsin Physician Services’ carrier medical director Stephen Boren, MD expressing similar concerns as the AMDA state chapters: the draft LCD reimburses home and domiciliary visits based on the frequency of visits and not medical necessity as required by Medicare. The letter states “if this draft LCD proposal is finalized, physicians will constantly fear that they are performing too many visits, because they would have no knowledge of how many visits would have been performed on this patient in the office setting.” To view the letter to from state chapter, click here. To view the ACP letter, click here .

Electronic submission of staffing data through the Payroll-Based Journal (PBJ) is required of all Long Term Care Facilities starting in 2016. Section 6106 of the Affordable Care Act (ACA) requires facilities to electronically submit direct care staffing information (including agency and contract staff) based on payroll and other auditable data. The data, when combined with census information, can then be used to not only report on the level of staff in each nursing home, but also to report on employee turnover and tenure, which can impact the quality of care delivered. Click here for more information.

CMS Surveyor Guidance for Medical Director Tag

On November 18, 2005, CMS implemented revised Interpretative Guidelines in the State Operations Manual, Appendix PP for the medical director Tag along with training materials for state surveyors. For 30 years, Medicare regulations have required medical directors in skilled nursing facilities. In 1987, The Omnibus Budget Reconciliation Act extended that requirement to nursing facilities. The functions of a medical director, codified in Title 42 483.75(i)(2), are to implement resident care policies and coordinate medical care in the facility.

For 30 years, Medicare regulations have required medical directors in skilled nursing facilities. In 1987, The Omnibus Budget Reconciliation Act extended that requirement to nursing facilities. The functions of a medical director, codified in Title 42 483.75(i)(2), are to implement resident care policies and coordinate medical care in the facility. It is very important to understand that the regulation has not changed, but there is additional guidance in the State Operations Manual, and the guidance is a reflection of already existing and long-standing AMDA policy: the role and responsibilities of the medical director. CMS has published the revised Interpretative Guidelines on its webpage.

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Frequently Asked Questions:

Question:What is AMDA's policy on collaborating with nurse practitioners/advance practice nurses to perform physician services in nursing facilities and skilled nursing facilities?

Answer:AMDA formed an ad hoc work group that developed an article entitled Collaborative and Supervisory Relationships Between Attending Physicians and Advanced Practice Nurses in Long-Term Care Facilities that was published in the Journal of the American Medical Directors Association in January 2011. The work group contained representation from the physician and advanced practice nursing communities as well as the American Academy of Family Physicians and the American College of Physicians. In addition, AMDA, the American Medical Association, the American College of Physicians, and the American Academy of Family Physicians all support collaboration and the physician's supervisory role. The following documents illustrate this point:

Physician Visits