As we recently reported, Section 6102 of the Affordable Care Act ("ACA") requires all nursing facility providers to have a Corporate Compliance Plan in effect by March 23, 2013. While the ACA required the Office of the Inspector General ("OIG") to promulgate regulations to provide guidance to facilities on the content, scope and requirements of this mandate, to date, the OIG has yet to issue any written materials. Last week, CMS advised that it is likely that such regulations will not be issued until later in 2013. CMS further stated that it will not enforce the statutory mandate until final regulations are issued. In the interim, providers should continue their existing compliance efforts, consistent with current guidance promulgated by the OIG.
If you have questions regarding the viability of your existing Corporate Compliance Plan, or would like assistance in developing a plan, please contact David Marshall at 717-620-2424.