Compliance Program Guidance
CMS has determined that all Medicare Contractors awarded contracts pursuant to the MMA shall have in place an effective compliance program. The compliance program may be tailored to the size and scope of the work to be performed under the MMA contract. CMS has published its own “Compliance Guidance for Fee-for-Service Contractors” that is available below. This document is based on the seven elements specified in the United States Sentencing Commission’s Sentencing Guidelines for Organizational Defendants, as amended. Contractors that are designing, implementing or evaluating their compliance programs may find it useful to refer to the CMS Compliance Guidance. However, it is not to be read as the sole pronouncement of desired substantive or procedural elements of an effective compliance program. Most importantly, an effective program is not static, but is constantly evolving towards the ultimate goal of being proactive rather than reactive.
- Page last Modified: 04/05/2012 10:13 AM
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