Wednesday, April 17, 2019

New Resources Available: RoP Phase 3 Compliance and Ethics Program

The American Health Care Association (AHCA) is pleased to announce new nursing center member resources to support creating or updating a Compliance and Ethics Program per 42 CFR § 483.85 in the Requirements of Participation (RoP) Phase 3. The new resources that are now available here, include:
  • AHCA toolkit
  • Sample checklist for compliance and ethics training
  • Sample tool for monitoring and auditing risk assessment
  • 10 webinars
Although the interpretive guidelines have not yet been published, 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. 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. Starting November 28, 2019, the Centers for Medicare & Medicaid Services (CMS) and state survey agencies will be authorized to issue survey deficiencies under F-Tag F895 to centers that do not have an effective compliance program.  Although this requirement does not go into effect until November, members should not wait to update and refine their compliance and ethics programs. We hope these resources will help you along the way.
For any questions on this topic, please email

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