CMS’s PBJ Version 2.6 Policy Manual CH 2: Definitions
Medical Directors and Consultants
For medical directors, CMS understands it may be difficult to identify the exact hours a
physician spends performing medical director activities versus primary care activities.
Data reported shall be auditable and able to be verified through either payroll, invoices,
and/or tied back to a contract. Facilities must use a reasonable methodology for
calculating and reporting the number of hours spent conducting primary responsibilities.
For example, if a medical director is contracted for a certain fee (e.g., per month) to
participate in Quality Improvement meetings and review a certain number of medical
records each month, the facility shall have a reasonable methodology for converting
those activities into the number of hours paid to work.
For consultants, data reported shall be auditable and able to be verified through either
payroll, invoices, and/or tied back to a contract. We understand it may be difficult to
identify the exact hours a specialist contractor (e.g., non-agency nursing staff) provides
services to residents. However, there shall be some expectation of accountability for
services provided. Facilities must use a reasonable methodology for calculating and
reporting the number of hours spent conducting primary responsibilities, based on
payments made for those services. Reminder: Practitioner (e.g., physician, nursing
practitioner) visits to residents billed to Medicare or another payer, hours for services
provided by hospice staff and private duty nurses shall not be reported.
Physical, Occupational, Respiratory, and Speech Therapy
Hours for physical, occupational, respiratory, and speech therapy services, regardless of
payer, shall be reported. If the therapist provides therapy to a nursing home resident
from 1pm to 2pm, and then therapy to a resident from 2pm to 3pm, then 2 hours would
be reported. If the therapy is being conducted concurrently or for a group, only the
absolute hours shall be reported. For example, if two residents are receiving 60 minutes
of therapy at the same time from 1pm to 2pm, only 1 hour shall be reported (not 2
hours for 120 minutes). Also, hours for services provided to non-nursing home
residents shall not be reported. For example, hours for outpatient therapy services
provided to community-based individuals shall not be reported.
Co-Located Facilities (e.g. Hospital-Based SNF)
Facilities need to report the hours that are allocated to the SNF/NF residents and shall
not include hours for staff providing services to non SNF/NF residents. For example, for
hospital-based facilities or assisted living communities that share staff with the nursing
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