There’s a new sheriff in town for compliance in one healthcare sector.

As of October 24, 2022, the Centers for Medicare & Medicaid Services (CMS) began surveying the effectiveness of compliance and ethics programs in skilled nursing facilities under Phase 3 of its Requirements of Participation (ROP).^[1]

Under ROPs, skilled nursing facilities were required to develop, implement, and maintain a compliance and ethics program that “has been reasonably designed, implemented, and enforced so that it is likely to be effective in preventing and detecting criminal, civil, and administrative violations under the Act and in promoting quality of care.”^[2]