By: Karina Gonzalez
Medical Directors are used in an administrative capacity to oversee all medical services and care, specifically referring to substance abuse programs and services. Increasingly, commercial healthcare plans are targeting their role in addictions treatment facilities and denying payment of claims based on audit findings that Medical Directors in Florida may be responsible for far too many treatment facilities and too many patients.
Does Florida have any specific requirements or published guidance on the number of treatment facilities or number of patients for which responsibility falls to the Medical Directors in addictions treatment?
Florida’s Administrative Code directed to substance abuse programs and services does not have any directive which talks about a restriction on the number of facilities or patients recommended for oversight by a Medical Director. It specifies that addictions receiving facilities, detoxification, intensive inpatient treatment, residential treatment, day or night treatment with host homes and medication and methadone maintenance treatment must designate a Medical Director who oversees all medical services. This Medical Director must hold a current license in the state of Florida.
Some guidance is found in the administrative code sections directed to licensed healthcare clinics and states that a Medical Director may not serve in that capacity for more than a maximum of five (5) healthcare clinics with a cumulative total of more than “200 employees and persons under contract with the healthcare clinic at any given time.” It also has a geographic restriction that a Medical Director cannot supervise a healthcare clinic more than 200 miles from any other healthcare clinic supervised by the same Director. Chapter 59A-33.013 F.A.C.
Florida’s Health Care Clinic Act does not apply to Substance Abuse facilities licensed under Chapter 397. The Act is aimed at clinics with non-physician owners that are not otherwise licensed to have a clinic license. Therefore as it applies to licensed Substance Abuse facilities there is no direct Florida prohibitions on the number of facilities for medical directorship.
What can Substance Abuse facilities to do?
They should set limits within their contracts and use the limitations designed for healthcare clinics as a guide. They should be cognizant of the number of Directorships their Medical Director is contracted to perform and consider not retaining Medical Directors who are in multiple facilities. Again, even though there are no clear restrictions on the number for substance abuse facilities, more than five may be too large of a number depending on the size of the facility. The service requirements must be reasonable as Medical Directors need sufficient time and resources to pursue best practices in the multiple management duties for which they have administrative oversight as well as on the clinical side; time and resources to manage issues such as appropriateness of care, quality of care, and medical necessity. Of course, it is incumbent on the physician who is performing as a Medical Director for various facilities to exercise good judgment when entering into Medical Directorship arrangements and disclose the number of directorships at the time of contracting.