Is your SNF ready to be surveyed on compliance?
ACA compliance programs must cover:
- Written compliance and ethics policies and procedures that:
- Reduce the risk of criminal, civil, and administrative violations
- Promote quality of care
- Designate a compliance contact to receive reports
- Include an anonymous way to report non-compliance without retribution
- Include disciplinary standards
- Apply to contractors and volunteers
- Assigned high-level personnel oversight for the compliance program
- Sufficient resources and authority for such high-level personnel
- Due care not to delegate substantial discretionary authority to individuals the SNF knew or should have known had a propensity to commit a crime
- Policies communicated to staff, contractors, and volunteers
- Auditing and monitoring
- Reporting system
- Consistent enforcement via discipline
- Corrective action
- Annual review (* the annual review is a new process for many SNFs - MPA recommends allowing yourself plenty of time to get this done)
We also recommend building a compliance program that meets OIG guidance and industry standards. MPA’s Checklist includes both ACA requirements and OIG standards!
