CMS Issues S&C Memo Concerning Civil Money Penalties

On March 22, 2013, CMS issued guidance to CMS regional offices directing use by regional offices of the CMP Analytic Tool as a guide to choose the type and amount of CMPs when a CMP was determined appropriate by the regional office.  The newly issued S&C memorandum, released on December 19, 2014, indicates that the CMP Analytic Tool is still to be used when establishing a CMP, but regional offices are no longer required to submit CMP Analytic Tool cases to CMS Central Office.  The S&C Memorandum contains the user guide for the CMP Analytic Tool, which is actually a computer software program internal to CMS.  The user guide describes how the tool is used.  CMS directs regional offices to use the toll in the calculation of each new or changed CMP imposed within a noncompliance cycle (each of those terms are defined in the S&C).  AHCA has been following the development of the CMP Analytic Tool very closely and is preparing analysis of this S&C memorandum.  IHCA will make that analysis available to members as soon as it is finished.