Reviewer Writes: Daily average FTE values should be higher than Peak FTE values

You may have to show them where you have peak and then how it isn't average. This seems obvious but you need to show the math. I find that peak is during shift change and they stabilize for the remainder of the shift. Typically, first shift is higher than second which is higher than third. So the peak is the overlap between first and second. How much of the overlap is caregivers and how long does the overlap last - one hour? half hour? Then you can show the population for first shift over 8 hours which will include the peak times (both for 3rd and for 2nd).  Otherwise, reviewers are just people and may not be healthcare experts. You have to be their guide.

Agreed, this is a thing reviewers look for because it's a common error on projects where peak is clearly lower, and those are the majority of projects. E.g. an office building or bank branch would only have a few visitors/customers at any given time but they'll add up over the workday to a higher average. Or a high-rise residential will have visitors coming and going all day with no extreme peak. They should be looking at project context before assuming something was calculated incorrectly - like, if your building had a large event space then peak would clearly be higher - but might not have had enough information here to make that judgement call.

A brief explanation will go a long way here - what's obvious to you after hours of work on the project is sometimes not clear at all to a reviewer who's just opened up the documents.

It sounds like the reviewer is thinking about peak visitors and transients, which work that way.

If you had three shifts, with 20, 10, and 10 people on each shift for example - then the average FTE per day is 40, and the peak is 20. 

Adjust if your building wasn't a three-shift healthcare project, but I think the comment is valid. If there were only one peak shift, then the two values would be equal.