Printer Friendly, PDF & Email

Board of directors oversight of skilled nursing facility compliance programs

Todd J. Selby ( is a Shareholder and Sean Fahey ( is an Attorney in the Indianapolis, Indiana, office of Hall Render.

Skilled nursing facilities (SNFs) are now required to implement a compliance and ethics program pursuant to the federal Requirements of Participation (RoPs) found in 42 C.F.R. § 483.85. It remains unclear how a compliance program should be designed due to proposed regulations and lack of guidance from the Centers for Medicare & Medicaid Services (CMS). One thing is certain, CMS will expect substantial oversight of the compliance program by the SNF’s board of directors.

This document is only available to members. Please log in or become a member.