Part 1: Medical Directors

by James C. Sherlock

The active presence of the medical director in a nursing home is vital to maintaining the quality of care. By overseeing medical practices, implementing care policies, ensuring compliance with professional standards, and, if required, butting heads with facility administrators and owners, the medical director plays a crucial role in safeguarding residents’ health and well-being.

Few physicians would tolerate the levels of understaffing, poor care, and dangerous policies driven by some out-of-state chains in too many Virginia nursing homes.  The results include neglect, abuse, and deaths of helpless people.

Many nursing homes do a great job of caring for their residents.  We thank all of you.  But public data support the conclusions that in some nursing homes:

• Medical directors are not present to the extent required by the patients’ needs or by law;  
• They do not effectively intervene on behalf of patients; and  
• Many are overextended.

The Case of Dr. Abbasi

In March 2025, a judge in one of the multiple scandals that erupted at Colonial Heights Rehabilitation and Nursing Center (Colonial Heights) in December of 2024 was asked to decide whether a physician, arrested and charged with elder abuse for what prosecutors called a “lack of oversight of patient care” in the death of a resident, should be allowed to continue practicing medicine at the facility. The defendant, Gohar Maqsood Abbasi, MD., was both the medical director at Colonial Heights and a mandated reporter. The judge decided that oversight of the practice of medicine was the state’s responsibility, not the court’s. He was right.  

In the pending criminal case, Dr. Abassi is innocent until proven guilty.  

Dr. Abbasi has an active license to practice medicine in Virginia. His license data indicates that he limits his commitments within the bounds of what should be doable:

• sees patients 5 days a week and spends 60% of his time at his primary practice address in Chester,
• participates in Medicare and Medicaid and accepts new patients in both,
• is subject to no Virginia Board of Medicine Notices or Orders, and
• has paid no malpractice claims.

Facilities licenses show he serves or has served as medical director at three nearby nursing homes:

• He was replaced as medical director at Colonial Heights (Lifeworks Rehab chain) effective 2025-12-08, a year after the raid. Colonial Heights averages 137 residents per day, 
• Henrico Health & Rehabilitation Center (Lifeworks Rehab), 108 residents per day. As Virginia’s only Special Focus Facility, Henrico Health and Rehab is designated by the state as, over time, the worst nursing home in the Commonwealth, and
• Canterbury Rehabilitation and Healthcare Center (Marquis Health Services), 177 residents per day, whose residents suffered the Commonwealth’s largest loss of life during COVID.

He discloses affiliations (see below) with:

• Group: Prime Care Health Services PC,
• Hospitals: John Randolph Medical Center and Bon Secours St. Francis Medical Center, and
• Nursing homes: Canterbury Rehabilitation and Healthcare Center and Henrico Health & Rehabilitation Center.

While the government charges Dr. Abbasi with malfeasance, the publicly available records do not help its case.  

He was not overcommitted. Two days a week serving as the medical director for those three facilities should have been sufficient. While the facilities did not help him by reporting that no medical director was on payroll, Medicare, for some unfathomable reason, allows direct provider billing for medical director services rather than facility billing. 

But the case raises complex and important questions well beyond this one instance about the enforcement of laws and regulations governing nursing home medical direction.

Public records provide both answers and questions. The conflicts among reports from the same providers are legion. But they speak loudly enough, even with and often especially because of the conflicts, that no commentary is required or offered.

It is the government’s business to deal with the issues raised.

Virginia

Take a look at the spreadsheet curated for this article.  Every nursing home in Virginia is there.

• It shows both the broad medical director commitments of some physicians and those who limit their obligations to three or fewer.  
• Some large and wealthy continuing-care communities have a full-time physician on staff.  
• Riverside, a major hospital chain with a large number of physicians in its employ, assigns staff physicians to serve as medical directors of its nursing facilities.
• Seaside Health Center at Atlantic Shores in Virginia Beach is an independent for-profit skilled nursing facility with no long-term care option.  It shows what can be done if a for-profit facility is committed to providing doctors to its patients.
• Saber Healthcare Group’s Clarksville Health & Rehab Center in Mecklenburg County reported 208 hours of medical director time in one quarter.
• Health Care Center Lucy Corr, an independent in Chesterfield, reported 526 hours of medical director and other physician time in that same quarter.

The data provided by facilities and physicians to federal and state governments are incoherent, contain gaps, are nonresponsive to federal and state requirements, or all three.  Federal and state laws and regulations governing medical directors are clear.  But the data submitted is highly inconsistent among:

Medicare and Medicaid billing data would help clarify the incoherence in the data, but there is no evidence of any attempt by the state or federal governments to do so.In September of 2024, a study published in the Journal of the American Geriatrics Society revealed critical findings about the presence and role of medical directors in U.S. nursing homes.  The criticisms are supported by government data showing what is happening in Virginia today.  The accompanying editorial The tip of the iceberg: A call to improve medical director presence, time, and training in US nursing facilities went unheeded in the Commonwealth.

Their finding that more than a third of US nursing facilities report zero medical director time represents a wake-up call for enforcement of the federal mandate for medical direction.

The spreadsheet shows that 48% of Virginia nursing homes reported zero medical director time in the second quarter of 2025.  That includes the two that still report Dr. Abbasi as their medical director.

Surprisingly, they report that surveyors rarely cite deficiencies related to medical direction.

State inspectors/surveyors reported the results of a survey of Colonial Heights conducted 12/18/2024 through 12/23/2024 and 12/26/2024-01/03/2025.  They reported a lengthy list of state regulations that Colonial Heights was not in compliance with.  Revisit reports were filed on 01/03/2025 and 03/26/2025.  

No mention of the medical director at Colonial Heights was made in any inspection report filed before or after his January 16, 2025, arrest.

Government Focus, Rules, and Data Relating to Medical Directors

HHS OIG’s Focus on Nursing Home Engagement of Medical Directors

In June 2025, the federal Department of Health and Human Services (HHS) Office of Inspector General (OIG) work plan was updated to include the Monitoring and Engagement of Medical Directors in Nursing Homes. CMS will begin conducting its reviews in 2026.

That project will:

review the regulatory requirements for medical directors in nursing homes, the barriers nursing homes have faced when implementing the regulations, and proactive takeaways to consider when analyzing your medical director’s arrangements and the documentation required to quantify the effectiveness of medical director services.  

The scope of the OIG’s focus will be in three areas:

• The extent in which medical directors performed required duties in nursing homes,
• the extent in which payroll-based journal data on medical directors’ hours are accurate and useful for oversight, and
• opportunities to improve oversight and transparency of nursing homes’ engagement and funding of medical directors through existing data or other monitoring mechanisms.

Opportunities abound.

Medical Director Responsibilities

An F Tag is a specific code used to identify a nursing home’s failure to comply with federal health and safety regulations during inspections.

The CMS State Operations Manual Appendix PP – Guidance to Surveyors for Long Term Care Facilities gathers the federal regulations that define the medical director’s federal responsibilities under F841. An attachment combines F841 guidance to inspectors with the Commonwealth’s own requirements. A scan of that document will help readers appreciate the breadth and depth of the medical director’s roles and responsibilities.

Virginia also requires the medical director to:

• Provid(e) temporary physician services when the admitting physician is not the attending physician, in order to assure that the resident has temporary medical orders;
• Provid(e) physician services in case of emergency in the event that the resident’s attending physician cannot be reached. Some Virginia medical directors have a lot on their plates other than that taxing job.

Some Virginia medical directors have a lot on their plates other than that taxing job.

Licenses of Facilities and of Medical Directors

Facilities and physicians are, of course, separately licensed. In Virginia, physician licenses are available here, and nursing homes list their medical directors on the third page of their license information here.

To find the medical director, select Nursing Homes, then enter the facility name. Start typing “Colonial Heights.” When the full name of that facility appears, click it. Now click on “show more” under “applications.” Click on the bottom (latest) one. Now, click on “Facility Information” in the upper right corner. You will see that Dr. Joseph McAfee is the medical director in the January 1, 2026, license update.  

If you traced it back, you would find that Dr. Abassi was replaced by Dr. McAfee in a license change dated 2025-12-08.

CFR § 424.519 Disclosure of affiliations

Upon CMS’s request, physicians and other eligible professionals must disclose any affiliations with other providers or suppliers that have experienced a “disclosable event.” CMS determines whether any of the disclosed affiliations poses an undue risk of fraud, waste, or abuse.

In practice, disclosure is not that dramatic.  

Most providers include disclosure of affiliations as an assumed duty or a prophylactic measure. Disclosures for doctors and clinicians are available through the Medicare Compare menu. Enter your state and the name of a specialty, a provider, or a group. You will see provider affiliations with groups, hospitals, nursing homes, home health agencies, hospices, and other entities.

Quarterly Payroll-Based Journal Daily Non-Nurse Staffing Reporting

Non-Nurse staffing provides very important information that CMS largely ignores.  It is there that we find the hours of the administrator, the medical director, other physicians, physician assistants, nurse practitioners, clinical nurse specialists, dietitians, pharmacists, and specialized therapists, among others.  None of the physician jobs currently count towards the Medicare Compare staffing rating.

Bottom Line

This article is about the safety and wellness of thousands of Virginians, the people for whom the laws and regulations cited here were written to protect.  All are frail, some recovering from surgeries, others with chronic diseases and dementia.  Many cannot walk or even get out of bed without assistance.  The data indicate that many need more physician supervision of their healthcare than they are receiving from doctors on their facilities’ payroll.  The Virginia Department of Health (VDH) will have to sort out, in its facility inspections, what is really happening.

For the VDH Office of Licensure and Certification (OLC).  

• Cross-checking, and perhaps cross-linking, physician license, facility license, facility medical director hours reports, and physician disclosure data will provide a fuller view of medical director commitments than any of those databases alone.  Finally, review the medical director’s Medicare and Medicaid billing records from the previous year.  Together, they complete the picture of what needs to be resolved during facility inspections.
• The HHS OIG is making violations of statutes and regulations by medical directors a major focus in 2026. Emphasis on F841 in inspections and surveys would support that effort.
• The American Medical Directors Association and the Society for Post-Acute and Long-Term Care Medicine have offered a model medical director contract since 2019. It would be useful during inspections to examine the contracts in effect.

For the General Assembly.  Virginia’s legislature may wish to consider setting a limit of three facilities per individual physician in the role of medical director, or five if they are close by and the physician performs medical director duties full-time. Given the existing regulation requiring the medical director’s emergency responses, Virginia law should set a specific maximum time from the medical director’s home to the facility.

For CMS. While focusing on the new compliance project, include the medical directors’ and other physicians’ time as components of the Medicare Compare staffing rating.

For Virginia’s Medical Societies and the Board of Medicine.  Please be part of the solution.