On Feb. 12, 2026, Florida's Agency for Health Care Administration (AHCA) proposed amendments to Florida Administrative Code Rules 59A-4.107 and 59A-4.0175, relating to the physician and medical director requirements for Florida nursing homes. AHCA's proposal seeks to align its medical director requirements with the 2025 legislative changes to section 400.141, Florida Statutes. The proposed changes would apply retroactively as of Jan. 1, 2026, and would revise the qualifications for medical directors.
Redefining the Standards for Nursing Homes' Medical Directors
As part of the State FY 2025-2026 Health and Human Services appropriations budget, the Florida legislature amended the medical director standards for nursing homes as part of a broader reform to nursing home governance. The state currently requires that each nursing home have a Florida-licensed physician serving as the nursing home's medical director. The director meets with the nursing home's risk management and quality assurance committee and participates in developing a comprehensive care plan for nursing home residents.
Prior to the 2025 legislative reforms, Florida did not require medical directors to have any certifications beyond a Florida medical license and hospital-admitting privileges (or alternatively, credentials from a national credentialing body). The reforms would require Florida nursing home medical directors to obtain specific medical director certification from the American Medical Directors Association or another association AHCA designates.
The proposed amendment maintains that a medical director must be a Florida-licensed physician but would also require the medical director to hold an active certification as a medical director or to "be in the process of seeking such certification." For the purpose of the proposed amendment, "in the process of seeking such certification" means that the nursing home medical director is actively engaged in obtaining certification as evidenced by his or her enrollment and participation in the Post-Acute and Long-Term Care Medical Association (PALTmed)'s Core Curriculum on Medical Direction in Post-Acute and Long-Term Care program or in another required certification program focused on clinical or management topics for post-acute and long-term care.
Applying for Medical Director Certification
The application process for PALTmed's initial certification for medical directors (CMD) can take up to one year to complete. The CMD credential remains valid for six years, and maintaining a CMD requires a physician to hold an active state medical license in good standing and to complete 120 continuing medical education (CME) credits, divided into 60 clinical CME credits and 60 management CME credits.
The proposed rule would require (i) any medical director appointed before Jan. 1, 2026, to complete such certification or recertification by Dec. 31, 2028, or (ii) any uncertified medical director appointed on or after Jan. 1, 2026, to complete the certification within three years of their appointment date.
Under the proposed amendment, AHCA would require each nursing home to provide information on its appointed medical director to the state. Each nursing home would need to submit proof of certification or progress toward certification for the medical director to AHCA as part of its licensure application for initial, renewal, or change of ownership. Nursing homes would also need to disclose such information if their medical director changes.
Key Takeaways on AHCA's Proposed Amendment
Interested stakeholders may find the proposed rule in the Florida Administrative Code and Administrative Register, and AHCA will accept public comments on the amendment until March 5, 2026.
*Special thanks to Associate Sven Kleinhans for contributing to this GT Alert.
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