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Annual Review,” “Compliance Program Risk Assessment,” and “Compliance Program Effectiveness Review” all mean the same thing: A comprehensive evaluation of the compliance program. The review evaluates each element of compliance and each risk area, identifies gaps, and includes a plan of action to close those gaps.
The Annual Review is not just mandatory. It’s essential to moving compliance forward. It gives your board or CEO a yardstick by which to measure the compliance programs they oversee. It gives compliance officers a list of successes to celebrate and challenges to work on in the coming year.
As of November 28, 2019, all skilled nursing facilities are required by law to conduct an annual review of their compliance programs. Providers who have not conducted an annual review by November 28, 2019 are in violation of the law. Providers have been on notice of this requirement since the regulation was released in 2016.
