Civil Money Penalty (CMP) Analytic Tool and Submission of CMP Tool Cases
• Civil Money Penalty Analytic Tool Case Submissions - The Centers for Medicare & Medicaid Services (CMS) is issuing the following
guidance to notify States that CMS Regional Offices (ROs) are required to continue to use the CMP Analytic Tool and guidance
in establishing CMPs, but are no longer required to submit Civil Money Penalty (CMP) Analytic Tool cases to the CMS Central
• Use of Civil Money Penalty Analytic Tool - On March 22, 2013, CMS issued guidance that all CMS ROs were required to use
this guidance and CMP Analytic Tool as a guide to choose the appropriate type of CMP to be imposed and to calculate the baseline
CMP amount, for all new enforcement cases when the CMS RO determines that a CMP is an appropriate enforcement remedy.
• Enhanced Enforcement Consistency – CMS issued the CMP Analytic Tool and guidance to promote more consistent application
of enforcement remedies for skilled nursing facilities (SNFs), nursing facilities (NFs), and dually-certified facilities (SNF/NFs)
(collectively referred to as “nursing homes” or “facility(ies)”).