On March 13, 2000, the Office of Inspector General for the Department of Health and Human Services ("OIG") published its compliance guidance for nursing facilities. While the document does not differ substantially from the OIG’s October 29, 1999, draft, the OIG responded to some comments raised by the nursing home industry and modified the guidance to articulate the OIG’s role vis-à-vis HCFA’s role in enforcement.
As with all its other compliance guidance reports, the OIG’s guidance for nursing homes calls for the seven essential elements articulated in the Federal Criminal Sentencing Guidelines:
1. Standards that address specific risk areas;
2. A compliance officer and compliance committee;