The day of reckoning for SNFs is fast approaching. On November 28, 2019, CMS and state survey agencies will be authorized to issue survey deficiencies under F-tag F895 to facilities that do not have an effective compliance program.
As we have seen, the government has been extolling the virtues of compliance programs for decades. The seven basic elements of a compliance program were first laid out in the Federal Sentencing Guidelines in 1991. For its part, the OIG issued its first draft voluntary Compliance Program Guidance for Nursing Facilities in 1999. More recently, the DOJ and OIG each issued guidance on how to evaluate the effectiveness of compliance programs.
Please join us to learn the timely steps that you need to take to ensure you have an effective compliance program.