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Developing a Patient-Centered Nursing Home Compliance Program that is 3E (Effective, Efficient, and Economical)

By | January 2019 | Compliance Programs
Published in Journal of Health Care Compliance - November - December 2018
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As discussed in the last issue, in less than one year (November 2019) all nursing facilities participating in the Medicare and Medicaid programs will be required to develop and implement a Compliance and Ethics Program. The challenge for nursing facilities is to establish a program that is appropriately focused on ensuring compliance with all applicable laws and regulations, as well as:

  • Health and safety of patients;
  • Quality of care;
  • Accuracy and completeness of documentation; and
  • Integrity of bills and claims for payment submitted to federal health care programs (e.g., Medicare and Medicaid), other third-party payers, and patients.

Moreover, in light of  the many requirements imposed on long-term care  (LTC) facilities under the revised conditions of participation (COPs) for Medicare and Medicaid, how can the obligation to implement and maintain a Compliance and Ethics Program be accomplished in a “3E” (i.e., effective, efficient, and economical) manner? The solution lies in aligning and integrating the mandated Compliance and Ethics Program with other key COP requirements related to:

  • Resident rights;
  • Patient “freedom from abuse, neglect, exploitation”
  • Quality of life;
  • Quality of care;
  • Quality Assurance and Performance Improvement; and
  • Training.

Through a centralized, comprehensive, and coordinated process for addressing these regulatory mandates, a nursing facility can develop its Compliance and Ethics Program in a 3E manner.

Editor's Note: This article was originally published in the November - December 2018 Edition of the Journal of Health Care Compliance. Published here with permission.

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