New Law Requires Certification of Medical Directors in Skilled Nursing Facilities and Imposes New Reporting Requirements 

October, 2021 - Lori Ferguson

Key Points

  • Skilled nursing facilities must ensure their medical directors are certified within five years of the date of hire or by January 1, 2027, for medical directors already working in a SNF
  • SNFs must report medical director certification status to CDPH by June 30, 2022
  • SNFs must report medical director changes to CDPH within 10 days of the change

Effective January 1, 2022, a skilled nursing facility (SNF) will be prohibited from contracting with a medical director unless that person is, or will be within 5 years, a Certified Medical Director by the American Board of Post-Acute and Long-Term Care Medicine (ABPLM) or equivalent organization, as determined by the California Department of Public Health (CDPH).

All free-standing SNFs are required to report the name and certification status of their medical director to CDPH no later than June 30, 2022. For this report a SNF must submit an HS 215A, resume, and proof of certification or progress toward certification to CDPH. The HS215A form also requires information regarding criminal history, facility/clinic involvement, and adverse actions. AB 749 mandates that a person already employed as a medical director in a SNF be certified by January 1, 2027.

A SNF will also be required to report any changes in its medical director within 10 calendar days of the change. When a change occurs, the SNF must submit the appropriate packet of information to notify CDPH, including an HS 215A form, resume, and proof of certification or progress toward certification.

Facilities applying for SNF licensure must also submit to CDPH the HS 215A form, the medical director's resume, the medical director's certification status, and, if not certified, the expected date of certification.

These provisions do not apply to SNFs that operate as a distinct part of a hospital (D/P SNF). A D/P SNF must designate a "qualified physician" as its medical director. A "qualified physician" is either (1) certified or will be certified as a Certified Medical Director by ABPLM or (2) board certified in a specialty that is "consistent with the type of care provided" in the SNF and whose role has been approved by the hospital's leadership. AB 749 identifies physical medicine and rehabilitation and pulmonology as examples of acceptable board certifications.


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