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Title
Civil Money Penalty (CMP) Analytic Tool and Submission of CMP Tool Cases
Memo #
15-16-NH
Posting Date
2014-12-19
Fiscal Year
2015
Summary
• 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 Office. • 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)”).
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