OIG Releases Compliance Guidance for Nursing Facilities
By Marisol Cooke
Director, Moss Adams Health Care Consulting Practice
By Kim Hodson
Senior Manager, Moss Adams Health Care Consulting Practice
Original Publish Date: February 4, 2025
The Office of Inspector General (OIG) issued new Nursing Facility Industry Segment-Specific Compliance Program Guidance tailored to the nursing facility industry. This update emphasizes the need for nursing facilities to strengthen their compliance efforts to align with federal and state health care laws and regulations.
Background
In November 2024, the Office of Inspector General released the Nursing Facility Industry Segment-Specific Compliance Program Guidance, which updates the previous nursing facility guidance issued by the OIG in 2000 and 2008.
The guidance is a companion document to the previous General Compliance Program Guidance released in November 2023, and is designed to complement the compliance program requirements of participation mandated by Medicare and Medicaid programs.
Key Highlights of the Guidance
Key takeaways from the guidance include emphasis on the seven elements of a compliance program, providing focused training and establishing audit and monitoring mechanisms.
Comprehensive Program Elements
Nursing facilities are encouraged to implement seven core elements in their compliance programs.
- Standards of conduct and written policies
- Designation of a compliance officer
- Regular employee training
- Effective lines of communication for reporting issues
- Auditing and monitoring procedures
- Enforcing compliance standards through discipline
- Corrective action plans for noncompliance
Targeted Training for Staff
Establish a training plan that focuses on risks identified in the nursing facility compliance guidance.
Enforcement and Monitoring
Facilities must establish mechanisms to monitor compliance continuously, ensuring adherence to the latest rules governing patient care, reimbursements, and reporting.
Next Steps
Below are action steps for nursing facilities.
Review and Update Compliance Programs
Evaluate current compliance frameworks against the OIG’s recommendations.
Educate and Train Staff
Provide role-specific training to empower employees with knowledge of compliance expectations including Medicare and Medicaid billing requirements.
Conduct Internal Audits
Regularly audit operations to identify and address vulnerabilities.
Appoint a Compliance Leader
Designate a compliance officer or team responsible for oversight and enforcement. Assess the need for multiple individuals to ensure compliance and quality are addressed.
Assess Risk and Vulnerabilities
Complete an organization wide risk assessment to assess for risks in compliance and quality of care. Prioritize risks and develop mitigation strategies to reduce exposure.
We’re Here to Help
For more information on the Nursing Facility Industry Segment-Specific Compliance Program Guidance, contact your Moss Adams professional.
Additional Resources