On September 30, 2008, the OIG updated its compliance program guidance for nursing facilities by publishing “Supplemental Compliance Program Guidance for Nursing Facilities.” This Supplemental Guidance is in response to changes in the way nursing facilities provide, and receive payment for, health care services. While the original Guidance (issued in 2000) focused on the development of a compliance program, the Supplemental Guidance further assists nursing facilities by helping them evaluate and refine their current compliance programs. The major areas covered by the Supplemental Guidance include a review of the OIG’s original Compliance Program Guidance, an overview of the Medicare and Medicaid Reimbursement Systems, a focus on newly emphasized fraud and abuse risk areas, the importance of an “Ethical Culture” and the self-reporting of violations of criminal, civil and administrative law.
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