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Title: Drafting Acceptable Allegations of Compliance and Plans of Correction

Presenter: Ken Burgess, Poyner Spruill, LLP

Over the past several years, the Centers for Medicare and Medicaid Services (CMS) implemented and utilized a revised format for Allegations of Compliance (AOCs) and Plans of Correction (POCs) that focused on “processes” and procedures that both cased noncompliance and were designed to correct it, causing much confusion among providers. Earlier this year, CMS returned to the former delineation of AOC and POC elements and, as a result, how to obtain past noncompliance and either a one-day civil money penalty or reduce daily CMPs, where a CMP is the remedy chosen by CMS for a non-compliant event.

This Webinar will include a review of an actual successful POC that avoided daily CMPs as an example, and will discuss recent trends at the State and Federal levels in citations of past noncompliance versus daily CMP imposition.