Mandatory Compliance Training for All Staff

Jeannine LeCompte, Publishing and Research Coordinator

The Centers for Medicare & Medicaid Services (CMS) estimates that billions of dollars are improperly spent every year due to fraud, waste, and abuse. As part of its ongoing program to counter and reduce this loss, CMS and the Office of Inspector General (OIG) have devised mandatory staff training programs for long-term care (LTC) facilities. While these programs have been in place for a while, cases still occur where LTCs are fined or otherwise punished for failing to provide the necessary training to all staff.

A review of punitive actions issued by the OIG reveals that one of the most common mistakes LTCs make is the failure to train all staff correctly in preventing fraud, waste, and abuse. This is not because the training programs do not exist—but simply that they are not applied to all staff, volunteers, governing body members, subcontractors, and vendors providing services to the facility.

All too often compliance training is only provided for those who are frontline staff, or who deal directly with compliance. Everyone in the facility has the moral, ethical, and legal duty to prevent fraud, waste, and abuse—and to report infractions.

In Medicare- and Medicaid-approved LTCs, all of the provided services are subject to the same stringent controls. It is an error to think that only medical services fall under this rule. All staff must receive training in avoiding fraud, waste, and abuse because compliance is everyone’s responsibility. There should also be a policy regarding sanctions for those employees who do not complete the required compliance training.

Facilities must show that they have applied due diligence and compliance in all aspects of their service provision, including building and equipment acquisition and maintenance, and non-medical care to residents.