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Long-term care requirements, Phase 3: Lessons learned

Tamar Abell (tbacompliance@gmail.com) is a compliance consultant with 25 years’ experience in long-term care, based in Chicago.

Phase 3 of the Centers for Medicare & Medicaid Services (CMS) long-term care facilities Requirements of Participation (RoP) are a few months away from being enforced on November 28, 2019.[1] Included in the requirements is “the operating organization for each facility must develop, implement, and maintain an effective compliance and ethics program.” The heart of any effective compliance program is the compliance committee. I have led and attended many compliance committee meetings over the years. These meetings have run the gamut from an occasion for donuts and coffee, to highly sophisticated analysis and discussions that would make the compliance gods smile. Whether you are just starting your journey in compliance or are a seasoned organization, here are some lessons I have learned in conducting effective compliance committee meetings, including the why, who, what, where, when, and how.

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