The AHCA has issued new resources for nursing center members to support creating or updating a Compliance and Ethics Program under Phase 3 of the Requirements of Participation (ROP). Starting November 28, 2019, the Centers for Medicare and Medicaid Services (CMS) and state survey agencies will be authorized to issue survey deficiencies under F-Tag 895 to centers that do not have an effective compliance program. 

AHCA’s resources rely on best practices for an effective compliance program, calling out provisions specific to the ROP. These resources also provide practical explanation and tips for how to create or update your compliance program.

The ROP Compliance and Ethics Program stems from the Office of Inspector General’s (OIG) long-standing guidance for the seven elements of a compliance program. At this time, CMS has yet to issue interpretive guidelines.

The new resources include:

• AHCA toolkit
• Sample checklist for compliance and ethics training
• Sample tool for monitoring and auditing risk assessment
• 10 webinars

Although this requirement does not go into effect until November, members should not wait to update and refine their compliance and ethics programs. For any questions on this topic, please email educate@ahca.org.