The OIG has added medical director engagement to its work plan, and the method is telling: comparing the medical director hours facilities report through Payroll Based Journal against what the regulations require the role to actually do. Under CMS requirements, a medical director must be actively involved in policy development, provider oversight, QAPI activities, and the facility assessment process.
The exposure is a mismatch between the two: hours reported that do not reflect real involvement, or real requirements with no documented involvement at all. These responsibilities already come up in surveys, and the work plan signals they will be examined more systematically.
This is one of those risks that is cheap to fix before anyone asks and expensive to explain afterward. Reconcile the PBJ hours, and make sure the medical director's fingerprints are visible in the record: policy sign-offs, QAPI minutes, facility assessment participation.
Bottom line for operators:
Check that your PBJ-reported medical director hours are accurate, and that the medical director's involvement in policies, QAPI, and the facility assessment is documented somewhere a reviewer can find it.