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The intersection of civil rights and the end-of-life care

Nancy J. Beckley ( is President of Nancy Beckley & Associates LLC, a rehab compliance consulting firm in Milwaukee, WI.

Enforcement actions, Centers for Medicare & Medicaid Services memorandums, Office of Inspector General reports, and survey and certification guidance have given providers multiple touch points to update their compliance risk assessment, develop additional compliance monitors, and determine opportunities for specialty audits. The U.S. Department of Health & Human Services’ Office for Civil Rights (OCR) issued guidance early on in the public health emergency, easing enforcement actions while at the same time asking providers to exercise caution.[1] There was no change in the laws that OCR enforces, and OCR has been swift to respond to complaints ending in favorable outcomes for the complainant, as well as guidance and resolution with those providers and agencies that were subjects of the complaint.

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