The ever evolving adult day care model is complementing log-term care in very unique ways.  This includes the addition of highly skilled nursing, physician, restorative and rehabilitative services often under the CMS certification as a Comprehensive Outpatient Rehabilitative Facility.  These programs take care-along-the-continuum to a special level.

In developing and operating a CORF the Centers for Medicare and Medicaid Services, (CORF) require that your governance include a Governing Body in Code I-505 which states:  “The facility must have a governing body that assumes full legal responsibility for establishing and implementing policies regarding the management and operation of the facility.”

In the ideal scenario this Governing Body may approve contracts for staffing and other products and services.  The same code, Section I-507 requires that this Governing Body appoint an administrator who:

  1. Is responsible for the overall management of the facility under the authority of the Governing Body
  2. Implements and enforces the facility’s policies and procedures
  3. Designates in writing, an individual who, in the absence of the administrator acts on behalf of the administrator; and
  4. Retains professional and administrative responsibility for all personnel providing facility services

The rule does not provide specific qualifications for Governing Body members, however, it stands to reason that at least most would be qualified clinicians.  After all, their work, recommendations and oversight pertain to and affect the services of credentialed professionals.  Accordingly, you would want people who have something meaningful to contribute to key areas such as:

  1. Treatment Plan Review
  2. Investigations of Patient Rights Violations, and
  3. Issues Involving Regulatory Compliance

Ensuring we make good decisions will surely involve sticking to the rules.  An added benefit will be making the kind of decisions that serve our rehabilitative program well and that includes whom we select to appoint to our Governing Body.

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