On November 20, Office of Inspector General (OIG) released Industry Segment-Specific Compliance Program Guidance for Skilled Nursing Facilities and Nursing Facilities (Nursing Facility ICPG).

The document is OIG’s updated and centralized source of voluntary compliance program guidance for nursing facilities.  Providers can use the ICPG along with OIG’s General Compliance Program Guidance (GCPG) to help identify their own risks and to implement effective compliance and quality programs to reduce those risks.

The ICPG’s program can help nursing facilities to reduce fraud, waste, and abuse; promote cost-effective and quality care; enhance the effectiveness of providers’ operations; and propel improvements in compliance, quality of care, and resident safety.

This Nursing Facility ICPG draws on insights and recommendations informed by: (1) findings and observations from the OIG’s decades of work in nursing facilities, including audits, evaluations, investigations, enforcement actions, and monitoring of Corporate Integrity Agreements (CIAs); (2) legal actions initiated and investigated by the OIG in collaboration with its government partners; (3) current enforcement priorities; and (4) engagements and discussions with nursing facility owners, operators, industry leaders, trade associations, resident advocacy groups, and other stakeholders. LeadingAge participated in the OIG’s outreach efforts for the ICPG.

Under the Centers for Medicare and Medicaid Services (CMS) Requirements of Participation (RoPs) Phase 3, implemented in 2019, nursing homes are required to maintain a compliance and ethics plan. The recommendations and practical guidance provided in the Nursing Facility ICPG and GCPG can support nursing facilities in meeting these compliance program requirements while also aiding adherence to other statutory and regulatory obligations.

LeadingAge will continue to review the ICPG for further potential educational opportunities for providers.