Compliance Program Guidance for Skilled Nursing Facilities

By: Gina Elkins, OHCC, CHC, Senior Director of Compliance and Regulatory Strategy, Privacy Officer, Functional Pathways 

Strong compliance programs help protect residents, strengthen care delivery, and support integrity within skilled nursing facilities. One year after the Office of Inspector General issued the updated Industry Segment Specific Compliance Program Guidance for Skilled Nursing Facilities, many organizations are evaluating how their programs measure up. 

Why This Guidance Matters

The guidance modernizes earlier publications and reinforces that compliance and quality of care must work together. It helps SNFs identify risks, strengthen processes, and ensure regulatory adherence.

Core Objectives

• Identify risk areas vulnerable to fraud, abuse, and quality failures
• Strengthen program effectiveness through proactive monitoring
• Integrate compliance efforts with quality-of-care initiatives

Key Risk Areas for SNFs

Quality of Care and Quality of Life. This includes staffing, care planning, medication safety, infection control, and resident protection.
Medicare and Medicaid Billing Requirements. Accurate documentation, coding, and prevention of duplicate or improper claims.
Federal Anti-Kickback Statute. Scrutiny of arrangements involving incentives, pharmacy contracts, and joint ventures.
Other Risk Areas. HIPAA, Stark Law, related-party transactions, and civil rights compliance.

Best Practices for Strong Compliance Programs

• Clear standards, policies, and procedures
• Defined program leadership and administration
• Employee and vendor screening
• Ongoing education and communication
• Monitoring, auditing, and internal reporting
• Consistent discipline for non-compliance
• Investigations with corrective actions

Recommendations for SNFs

The updated guidance provides a roadmap for reducing risk and improving outcomes. Following these practices supports resident safety and ensures participation in federal healthcare programs.

• Conduct routine risk assessments and billing audits.
• Integrate compliance with quality improvement.
• Ensure leadership engagement.
• Use data analytics to identify trends.