Revision of Civil Money Penalty (CMP) Policies and CMP Analytic Tool
• Revisions to CMP Tool: When noncompliance exists, enforcement remedies, such as civil money penalties (CMPs), are intended
to promote a swift return to substantial compliance for a sustained period of time, preventing future noncompliance. To increase
national consistency in imposing CMPs, the Centers for Medicare & Medicaid Services (CMS) is revising the CMP analytic tool
in the following areas which are further explained within this policy memorandum:
• Past Noncompliance;
• Per Instance CMP is the Default for Noncompliance Existed Before the Survey;
• Per Day CMP is the Default for Noncompliance Existing During the Survey and Beyond;
• Revisit Timing; and
• Review of High CMPs.
• This policy memo replaces S&C Memo 15-16-NH: The prior versions of the CMP Tool are obsolete, as of the effective date of
this memo, July 17, 2017.