OIG Issues Voluntary Compliance Guide for Nursing Homes
(Dec. 2, 2024) The U.S. Department of Health and Human Services (HHS) Office of Inspector General (OIG) released voluntary compliance program guidance for nursing homes on Nov. 20th. The Industry Segment-Specific Compliance Program Guidance for Skilled Nursing Facilities and Nursing Facilities (ICPG) is intended to assist nursing homes in identifying their risks and in implementing effective compliance and quality programs to mitigate those risks. The Nursing Facility ICPG, together with OIG’s General Compliance Program Guidance (GCPG) for all health care sectors, serves as OIG’s updated and centralized source of voluntary compliance program guidance for nursing facilities.
The ICPG is not mandatory, but its recommendations can help nursing homes to satisfy the Centers for Medicare and Medicaid Services (CMS) requirement to maintain a compliance and ethics plan. The ICPG can also assist in meeting other Requirements of Participation including medication management, appropriate care planning, person-centered care in the context of changing demographics, and staffing. It identifies four high-level risk areas which are subdivided into more specific risk areas:
- Quality of Care and Quality of Life
- Medicare and Medicaid Billing Requirements
- Federal Anti-Kickback Statute
- Other Risk Areas (e.g., related party transactions, physician self-referral, anti-supplementation, Health Insurance Portability and Accountability Act (HIPAA), civil rights)
Each risk area includes concrete considerations and recommendations to respond to risks. The ICPG further includes recommendations related to the responsibilities and training of various individuals and groups involved in the facility's compliance program and the risk assessment, review, and monitoring processes.
More information is available from LeadingAge National here.
Contact: Karen Lipson, klipson@leadingageny.org