For SNFs, accurate PBJ reporting of medical director hours is now a direct compliance risk area, as OIG has announced a formal evaluation tied to F-tag F841 that could escalate to CMS enforcement and survey focus. Facilities should audit medical director documentation, including QAPI participation, policy involvement, and time records, before findings from the OIG’s 2027 report begin shaping new federal requirements.
State bill limits SNF medical director coverage, adds training rules
Lawmakers in Maryland are considering legislation this week to impose new qualifications for nursing home medical directors and limit them to covering two facilities each.
“Workforce challenges already make it very difficult for nursing homes to recruit and retain medical directors, and the two facility limit per director would exacerbate these challenges.”
— McKnight’s Long-Term Care News, February 23, 2026
Compliance spotlight turns to medical directors as responsibilities grow
Concerns about nursing homes’ reporting of medical directors’ hours using the Payroll-Based Journal system have raised questions about whether they are actually integral to implementing resident care policies, coordinating medical care, and participating in quality assessment and assurance activities, the OIG said.
“The facility must identify how the medical director will fulfill those responsibilities, and if that person is also an attending physician in the facility, there needs to be a process to ensure there’s no concerns with the medical director monitoring their own performance.”
— McKnight’s Long-Term Care News, February 4, 2026
Inside New and High-Risk Compliance Issues Arising from OIG Recommendations and CMS Regulations
Under CMS regulations, medical directors must be actively involved in policy development, provider oversight, QAPI activities, and the facility assessment process. These responsibilities are reviewed during surveys and are currently under scrutiny, “quietly announced” by the OIG through a work plan for medical directors.
“They’re going to be looking at medical director engagement and PBJ reporting hours of the medical directors. If reported hours are inaccurate or insufficient to reflect required involvement, facilities may face compliance concerns.”
— Skilled Nursing News, January 23, 2026
