Last month, the OIG published a draft guidance to

supplement its earlier 2000 Compliance Program Guidance for

Nursing Facilities. The April 2008 Draft OIG Supplemental

Compliance Program Guidance for Nursing Facilities1 further

expands upon potential risk areas, which once finalized will be incorporated with the earlier 2000 guidance into one

document.

Before delving into this new 2008 guidance document, facility staff may want to review the 2000 guidance which identifies elements of an effective compliance program. Briefly, the 2000 OIG guidance2 outlined seven elements which could be incorporated into a three-phase compliance program implementation plan:

Phase 1: Evaluation of significant risk areas for the

nursing facility, based upon the type of services offered,

the facility's performance history, and potential fraud

and abuse areas.

Phase 2: Program development including identifying

audit tools, providing employee education, and creating

effective lines of communication.

Phase 3: Conducting ongoing auditing and monitoring,

with periodic review of the program to be sure that it is

effective and current.

The April 2008 draft guidance is devoted to areas identified as potential fraud and abuse risk areas, i.e., those areas that "are currently of concern to the enforcement community." The following provides a brief overview of many of the issues raised under key topic areas.

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