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ACA Compliance Checklist for SNFs!

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ACA Compliance Checklist for SNFs


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!