When the Affordable Care Act was passed in 2010 it included section 6102 requiring nursing facilities to have an effective compliance program. However, CMS didn’t issue a final regulation on this until October of 2016. Following the final rule, we learned that CMS would not enforce the compliance program requirement until November of 2019.
While three years might sound like ample time, it will take most organizations over a year to truly design and implement an effective compliance program. If you haven’t started yet, I’d urge you to start right away. If you are new to compliance programs in the nursing facility space, study the CMS compliance program guidance documents and implement the mandatory compliance program requirements for 2019.
Quality of Care
- Comprehensive Resident Care Plans
- Medication Management
- Appropriate Use of Psychotropic Medications
- Resident Safety
- Promoting Resident Safety
- Resident Interactions
- Staff Screening
- Submission of Accurate Claims
- Proper Reporting of Resident Case-Mix by SNFs
- Therapy Services
- Screening for Excluded Individuals and Entities
- Restorative and Personal Care Services
- The Federal Anti-Kickback Statute
- Free Goods and Services
- Service Contracts
- Non-Physician Services
- Physician Services
- Price Reductions
- Reserved Bed Payments
- HIPAA Privacy and Security Rules
Tune in to my upcoming webinar, Is Your SNF Ready for the 2019 Compliance Requirements?, to make sure you are prepared. I’ll talk about nursing facility compliance risk areas and much, much, more. In this webinar, you’ll learn how to, prepare your organization for 2019 compliance requirements, understand the guidelines and risks of noncompliance, and design and implement an effective compliance program.