Personnel Requirements of a Florida Home Health Agency – Part 5

In this last installment of our five-part series on The Personnel Requirements of a Florida Home Health Agency, we will cover the position of home health agency Medical Director.

The first and most important point to keep in mind is that Florida does not require home health agencies to have a medical director. In the past, some unscrupulous agencies used the veil of the medical director position to have an excuse to pay providers who referred patients to them (which is against the law).  Some agencies had several medical directors!  Because of that, the State of Florida developed specific and strict criteria for the medical director position for those agencies who would like to add this position to their organization.

If an agency has a medical director, it must:

  • Have only one. The days of multiple medical directors are over.
  • Have a written contract with the physician that has at least a one-year term, and specify the services that will be provided by the physician.  Some common tasks performed by medical directors include participating in the quality assurance process by attending meetings, reviewing medical charts, assisting with quality studies of clinical patterns or trends observed in the patient population, providing guidance to the agency leaders on clinical issues, etc.
  • Include specific payment that is at fair market value.  We’ve seen payment based on flat fees as well as hourly rates.  Again, the concept of fair market value prevents an agency from remunerating a physician an exorbitant sum for supposedly performing medical director duties, especially if the physician also refers patients to the agency, which is common.   The specified fee also cannot vary.  In other words, the agency cannot pay the physician at $150 per hour in January and at $250 per hour in March unless there is a change in the market value of physician medical director services.
  • Finally, the medical director must submit invoices that detail the work performed, the dates on which that work was performed, and the duration of that work; these invoices must match the payments made to the doctor.

A medical director can be a very valuable team member to the home health agency, providing solid guidance that translates into better patient outcomes and, ideally, lower patient care costs.  Unfortunately, some hucksters’ past behavior has prompted the intense scrutiny by AHCA in this area. However, if an agency is truly utilizing the services of a medical director and follows these simple, sensible guidelines, it should be able to proceed confidently in the interests of quality care.

 

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