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Revision of Civil Money Penalty (CMP) Policies and CMP Analytic Tool
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Posting Date
Fiscal Year
• 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.