The Affordable Care Act moved compliance programs from "recommended" to mandatory.
Many of us thought recommended really meant "mandatory" anyway but now it is law.
Problem is, the Obama administration has not gotten around to writing the implementing regulations. Since LTCFs were supposed to be in compliance by March 23, 2013 this is sort of awkward.
There is guidance available, and there are a multitude of good reasons to have a compliance program, so providers should be moving forward with programs. To do otherwise is akin to driving a car without a seat belt.
Look for a series of commentaries over the next two months on the techniques and advantages of a vigorous compliance program.