Management Performance Associates

Full Service Compliance Programs

MPA can help you handle the entire compliance puzzle, or help you with the missing piece of your program. For a detailed list of services, see MPA’s Compliance Services.

Invest in an Effective Program

Your Compliance Program will not be a binder of documents gathering dust on a shelf. MPA’s services provide a program that is effectively managed as part of your day-to-day operations. The Compliance Program will be comprehensive in that it will address healthcare requirements and reduce your risk—and will also target in detail those areas identified by your organization as high priority. MPA strives to advance, but not duplicate, your existing compliance efforts.

The MPA Difference

MPA saw a need for comprehensive compliance programs—not just an unused “binder” program, but fully implemented programs with strategic oversight. We also saw, with the homes that we manage, that hiring a full time employee or paying an attorney an hourly rate to build a compliance program from the ground up is cost prohibitive. It works similarly to our management and business office management services. MPA’s compliance services are tailored to each SNF, working closely with their existing staff and procedures. Instead of each community building a compliance program from scratch, MPA brings its resources and multi-disciplinary team to multiple clients—and shares best practices among these clients, improving compliance efforts for all.

Comprehensive Compliance Programs include…

For a fixed annual fee, you will receive:

I.               Assessment of Compliance Status

MPA will work with your staff to conduct a baseline assessment of your compliance operations. This assessment will examine the level of implementation of the seven compliance program elements recommended by the Office of Inspector General (OIG):

  • Written policies, procedures, and standards of conduct
  • A designated compliance officer and compliance committee
  • An effective training and education program
  • Effective lines of communication
  • Enforcement of standards through well-publicized disciplinary guidelines
  • Internal monitoring and auditing
  • Prompt response to detected offenses and corrective action

MPA will assess the extent to which your organization addresses compliance risks in the following categories:

  • Quality of Care
  • Resident Rights & Safety
  • Employee Screening
  • Billing and Claims Submission
  • Cost Reporting
  • Kickbacks, Inducements and Self-Referrals
  • Creation and Retention of Records
  • Anti-Supplementation
  • Medicare Part D Plan Selection

II.              Compliance Program Policy Development

MPA will design a Compliance Program Policy for your organization. This Policy will build on existing compliance practices, and describe the policies and procedures that make up the backbone of the Compliance Program:

  • Compliance officer and compliance committee
  • Effective training and education
  • Effective lines of communication
  • Enforcing standards through well-publicized disciplinary guidelines
  • Responding promptly to detected offenses and developing  corrective action

The Compliance Program Policy will also include a Code of Conduct setting forth guiding compliance principles.

III.            Development of Risk Area Policies and Procedures  

MPA will provide policy and procedure forms to address each area of compliance risk:

  • Quality of Care
  • Resident Rights
  • Employee Screening
  • Billing and Claims Submission
  • Cost Reporting
  • Kickbacks, Inducements and Self-Referrals;
  • Creation and Retention of Records
  • HIPAA Privacy, Security and Breach Notification
  • Medicare Part D
  • Anti-Supplementation

IV.            Training and Education

MPA will develop a customized compliance training session for your employees and board members. The presentation can be used for annual compliance education and to train new employees during orientation.

Training will be administered through MPA’s Compliance Client Gateway. Through the Gateway, your employees can complete training on their own time. The Gateway tracks employee completion of training for your records. The Gateway can also be used to distribute your Compliance Program Policy and Code of Conduct to employees, and obtain and track employee agreement to follow these policies.

V.             Auditing and Monitoring

MPA will work with your team to develop an auditing strategy to benchmark and measure progress in each area of compliance risk. MPA and your staff will work together to analyze audit results, identify areas needing improvement, update goals, and develop a specific plan to achieve these new goals.

VI.            Program Updates

MPA will provide ongoing updates to the Compliance Program based on new regulations, OIG guidance, and improvements in best practices.

VII.          Annual Review

MPA will conduct an annual evaluation of the Compliance Program, evaluating performance in each risk area, and the success and challenges of the Compliance Program overall. The annual review will include recommendations for improving the Compliance Program in the following year.

VIII.         Ongoing Corporate Support

MPA will serve as a resource to your Compliance Officer, and will be available by phone and email to answer questions that may arise regarding the Compliance Program and its policies and procedures.

The above services are designed to keep your compliance program effective, when performed on an annual basis and combined with the efforts of your staff.

For more information, see MPA’s Compliance Services, or contact:
Margaret Scavotto
Director of Compliance Services
314-394-2222 ext. 24
[email protected]



I have never seen a compliance program this comprehensive.

- Bart Becker, Administrator, DeKalb County Rehab & Nursing Center