Phase 3 – Compliance and Ethics

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Start Preparing Your Programs Now!

Implementing a Compliance and Ethics Program takes time and effort. With Phase 3 of the RoP fast approaching (effective date 11/28/19), providers need to prepare for F895: Compliance and Ethics Program. This is a new regulatory component that requires facilities to have:

  • Written policies and procedures related to compliance and ethics.
  • High-level personnel involvement for oversight of the program.
  • Sufficient resources and authority.
  • An effective communication strategy that includes employees, volunteers and contractors.
  • Effective monitoring and auditing procedures to detect potential and actual violations.
  • Methods for reporting potential or actual violations, including an anonymous method.
  • Evidence of consistent enforcement of Compliance and Ethics policy and procedures.
  • Evidence of proper action taken following a violation to prevent reoccurrence.

Organizations with 5 or more facilities will be facing additional requirements including mandatory annual training, assigning a designated Corporate Compliance Officer and Compliance Liaison in each facility and implementing a process for an annual review of the program.

Implementation of an effective program will promote quality of life for your residents in addition to reducing the risk of criminal, civil and administrative violations.

For more information on the CMS requirements under F895 click here. If you have questions or if you would like to schedule a review of your program, please contact Coretactics, Inc.

Sarah Ragone, MSPT, RAC-CT
VP of Reimbursement & Education

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