OIG Nursing Facility Compliance Guidance
OIG emphasized effective compliance programs and facility-specific risk assessment.
OIG guidanceConnected clinical governance for skilled nursing
CMS and OIG are increasing their focus on the care delivered to nursing home residents by outside clinical providers — and whether facilities have the visibility and controls to understand what is happening.
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Interactive portal demoSee CliniCouncil in ActionExplore CliniCouncil for Your FacilityRegulatory change
Three developments are bringing outside clinical care, Medical Director oversight, and facility-level controls into sharper focus.
OIG emphasized effective compliance programs and facility-specific risk assessment.
OIG guidanceCMS clarified expectations for medical-care coordination, policy implementation, and QAA/QAPI follow-through.
CMS guidanceOIG is examining Part B services and whether nursing homes have effective compliance programs and adequate controls.
OIG Work PlanOIG has identified a critical visibility issue:
“NHs may not be aware of the services that the providers bill directly to Medicare.”
Office of Inspector General — Medicare Part B services provided to nursing-home residents
OIG's current work is examining whether nursing homes have effective compliance programs and adequate controls over care provided to their residents. The provider remains responsible for independently submitted claims.
The governance gap
Illustrative example · one resident · seven days
Would your Administrator know?
Would your Medical Director know?
Frequent clinical care is not inherently inappropriate. A medically complex resident may appropriately require multiple specialists. The governance question is whether the facility and Medical Director can see the complete clinical picture and coordinate care when necessary.
The connected layer
CliniCouncil connects the clinical activity that currently lives across contracts, credentialing files, schedules, reports, emails, clinical organizations, Medical Director workflows, and QAPI.
See CliniCouncil in action
This is where facility leaders can see and manage the outside clinical activity occurring in their facility.
Dr. Smith's license expires in 28 days.
Collaborative by design
Clinical partners are essential members of the nursing-home care team. CliniCouncil is not designed to interfere with clinical judgment or turn facilities into billing auditors. It gives strong clinical organizations a structured way to demonstrate their credentials, schedules, services, recommendations, documentation, and collaboration with the facility.
AI-assisted review
CliniCouncil can identify patterns that may deserve human review. It does not determine fraud, abuse, medical necessity, or billing compliance.
Review period: September 7–13
Encounter frequency exceeded the facility's established review threshold.
Provide clinical context or supporting documentation if appropriate.
Review the overall clinical pattern and determine whether additional coordination is appropriate.
The Provider Owns the Encounter and Its Billing.
The Facility Owns Its Regulatory Responsibilities.
The Medical Director Coordinates Medical Care.
CliniCouncil Connects the Three.
One connected clinical picture
Residents don't experience healthcare as separate companies, contracts, service lines, or billing systems. They experience one continuum of care.
CliniCouncil gives Skilled Nursing Facilities, Medical Directors, and Clinical Partners the shared infrastructure to make that care visible, coordinated, documented, and accountable.