Background
As part of the Requirements
of Participation (RoP) published October 2016, nursing centers must
have a Compliance and Ethics Program that meets certain requirements. Starting
November 28, 2019, CMS and state survey agencies will be authorized to issue
survey deficiencies under federal Ftag F895 to facilities that do not have an
effective Compliance Program.
CMS has not yet issued guidance about how F895 will be
interpreted, but AHCA encourages nursing centers to review the requirements at 42
CFR § 483.85 and begin making changes to comply.
AHCA Provider Member Resources
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Webinar and tools in ahcancalED:
AHCA
has a webinar series and resources to support members in developing or
adapting their existing program to meet this requirement.
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Designing and Implementing a Corporate Compliance
Manual (2013) – provides in depth background on creating a
Compliance Program including checklists and sample language. This Manual
is based on the OIG’s guidance from 2000 and 2008 (linked on the side
bar) and was developed prior to the issuance of the
RoPs in 2016. The Compliance and Ethics requirements in the RoPs were
informed by the earlier OIG guidance; however, nursing centers should
adapt as needed to ensure compliance with current federal and state
requirements.
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Sample Policies and Procedures for Risk
Management (2013)
The
Sample Policies and Procedures were developed prior to the final
Requirements of Participation. Nursing centers should adapt as needed to
ensure compliance with current federal and
state requirements.