In the November 2017 issue of Compliance Today, the monthly magazine of the Health Care Compliance Association (HCCA), Gina M. Riddell, MPA-CHA, CHC, writes that nursing facility providers are “required to design and implement a compliance and ethics program... effective as of November 28, 2016, but with a three-part implementation process that spans a three year period.” Without such a program in place, nursing facilities will eventually face penalties; Riddell shares that “although nursing facilities [were] required to be in compliance by November 28, 2017, this regulation will not be enforced until November 28, 2019.”
The statute governing this rule, 42 CFR 483.85, “now formally requires nursing facilities to develop, implement, and maintain programs that consist of eight elements (for organizations with less than five facilities) and eleven elements (for organizations with five or more facilities). These elements are:
Riddell also outlines the three additional elements, as mentioned earlier, that are required for organizations that have five or more facilities. These additional elements are:
Since we have passed the deadline of November 28, 2017, programs that meet these requirements must now be in place. In conclusion, Riddell recommends that “nursing facility organizations not only develop, implement, and revise a compliance and ethics program internally, but seek outside legal review and analysis to confirm compliance with federal requirements.”
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All quotes are taken from:
Riddell, Gina M., “Compliance Programs for Nursing Facility Providers,” Compliance Today, November 2017, (pp. 52-4).
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