Key Points:

• Skilled nursing facilities must have a certified medical director, with the final deadline for compliance of January 1, 2027
• SNFs must report medical director certification status to CDPH
• SNFs may be subject to deficiencies or enforcement actions for noncompliance

Skilled nursing facilities (SNF) are prohibited from contracting with a medical director unless that person is a Certified Medical Director. For medical directors already employed in a SNF on January 1, 2022, they have until January 1, 2027, to become certified through PALTMed, the Post-Acute and Long-Term Care Medical Association (previously, the American Board of Post-Acute and Long-Term Care Medicine (ABPLM)).

All free-standing SNFs are required to report the name and certification status of their medical director to CDPH. For this report, a SNF must submit an HS 215A, resume, and proof of certification to CDPH. A SNF must also report to CDPH when there is a change in their medical director and facility licensing generally requires submission of medical director information.

As of August 2026, CDPH reports that its records show only 22% compliance with the medical director certification requirements throughout the state. It is unclear whether that number comes from a lack of reporting or a lack of certification. According to CDPH guidance, SNFs that are not in compliance with the “medical director reporting requirements may be subject to a deficiency and enforcement actions.”

SNFs should confirm that they completed the required reporting to confirm their medical director certification to CDPH. Any SNFs still operating with a non-certified medical director should confirm their compliance by the deadline or come up with an individual compliance plan. Unfortunately, based on the PALTMed website, it appears that the next available core curriculum class, required as part of certification, is not scheduled until February 2027. At this time, CDPH does not have a standard mechanism to request an extension.

These provisions do not apply to SNFs that operate as a distinct part of a hospital (D/P SNF). A D/P SNF must designate a “qualified physician” as its medical director. A “qualified physician” is either (1) certified or will be certified as a Certified Medical Director by PALTMed or (2) board certified in a specialty that is “consistent with the type of care provided” in the SNF and whose role has been approved by the hospital’s leadership.