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CMS Final Rule: Compliance and ethics programs

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Providers may find they are meeting some of the requirements already. Lyn Bentley, MSW, Vice President, Quality & Regulatory Affairs, the American Health Care Association (AHCA), notes, “It is important for providers to review the expectations of their compliance program and the rule, and determine what they are already doing that meets the requirements. Determine a process to combine these activities into a formalized program that meets the elements of the rule. The next step is to identify the gap areas and develop a plan for how to fill those gaps.”

Over the years, the key operational modifier used to describe compliance programs has been the word “effective.” To be effective, it is essential that compliance and ethics programs are given full and robust support from the board of directors. Anything less would be counterproductive and ineffective.

Alan C. Horowitz, Esq., RN, is a partner at Arnall Golden Gregory. He is a former assistant regional counsel, Office of the General Counsel, U.S. Department of Health and Human Services. He also has clinical healthcare experience as a registered respiratory therapist and registered nurse. He can be reached at



Alan C. Horowitz

Partner at Arnall Golden Gregory

Alan C. Horowitz

Alan C. Horowitz, Esq., is a partner at...