A lot has been written and said about nursing facility (NF) corporate compliance since the Office of Inspector General (OIG) first published voluntary guidance in March 2000. Recently, the discussion intensified when the OIG published a supplement to its 2000 guidance, and encouraged assisted living and other long term care providers, not just NF providers, to establish and maintain effective compliance programs, with the goal to improve quality of care and services. We know from experience that one of the greatest obstacles to effective corporate compliance is company programs that are overly-complex, hard to understand and hard to manage. The OIG expects all owners, managers and employees, from owners and Board members to front-line staff, to understand the compliance program and participate in it actively. For that to happen, you have to know how to design, build and implement a compliance program; as well as understand the legal and practical benefits for implementing a program. To do that, we’re going to create web-based guidance, specifically for long term care providers, comparing a compliance program to something in the real world that everybody knows something about – houses. In this web-based instruction, we’ve compared designing, building, maintaining and revising a NF compliance program to designing, building, maintaining and repairing a house. AHCA has contracted with Ken Burgess, a long term care attorney with Poyner Spruill, to draft this guidance.
Please check this site routinely to learn in small incremental steps how to design and implement a corporate compliance program. We will address all the following compliance concepts in the future, and will post specific materials and checklists. Each time we post new information, we will follow-up with a AHCA sponsored webinar, which will be led by Ken Burgess and a compliance officer from the Long Term Care Consortium (LTCC), ensuring that the practical/operational issues are well-covered: