Compliance and Ethics Program Effectiveness Is the Goal
This Bulletin is brought to you by AHLA’s Post-Acute and Long Term Services Practice Group.
- November 26, 2024
- Sarah Couture, RN, CHC, CHRC, CHPC , Couture Compliance
We know that having a skilled nursing facility (SNF) compliance and ethics program is required. The Centers for Medicare & Medicaid Services (CMS) published the first Requirements of Participation for long-term care facilities in 1989. Recent updates, which were effective November 28, 2016, prioritize modernization of the requirements “to reflect the substantial advances that have been made over the past several years in the theory and practice of service delivery and safety.” In addition to updating the approach to skilled nursing quality and practice, the final rule requires that SNFs have a compliance and ethics program. The prescriptive requirements are based on the longstanding “seven elements” of an effective compliance program, which are further tailored to the nuances of a SNF. Some requirements are varied based on the organization’s size, resources, and complexity. SNFs have specific requirements to follow regarding the compliance and ethics program, and CMS surveyors have been given guidance for assessing the programs.
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