3 Compliance Rules For Skilled Nursing Facilities

CMS won’t be enforcing the Affordable Care Act’s Skilled Nursing Facilities compliance requirement until November of 2019. That may sound like a long way off, but it will take most organizations over a year to truly design and implement an effective compliance program. If you haven’t started yet, you’re already behind.

Experienced compliance professionals can name the seven elements of an effective compliance program off the top of their heads. However, the requirements of a nursing facility compliance program are super different. All nursing facilities are required to abide by the core eight compliance elements. However, there are three additional requirements for organizations with five or more facilities. In addition to all of the other requirements, operating organizations that operate five or more facilities must also include, at a minimum, the following components in their compliance and ethics program:

1

A mandatory annual training program on the operating organization's compliance and ethics program.

2

A designated compliance officer for whom the operating organization's compliance and ethics program is a major responsibility. This individual must report directly to the operating organization's governing body and not be subordinate to the general counsel, chief financial officer or chief operating officer.

3

Designated compliance liaisons located at each of the operating organization's facilities.

It’s important to remember that even when your organization feels like it’s met all the requirements of an effective compliance program, there’s always more to do. Compliance work never really ends and a review of the compliance program will be required annually. The operating organization for each facility must review its compliance and ethics program annually and revise its program as needed to reflect changes in all applicable laws or regulations and within the operating organization and its facilities to improve its performance in deterring, reducing, and detecting violations under the Act and in promoting quality of care.

Download this free eBrief, Understanding the Unique Challenges Nursing Facilities Face, to prepare your organization for the 2019 requirements and learn the 8 Core Skilled Nursing Facility Requirements, the 3 Ultra-Specific Additional SNF Requirements, and get Free Resources to Help you Super Prepare.