Jeannine LeCompte, Publishing and Research Coordinator
Although Quality Assurance Performance Improvement (QAPI) programs and Compliance and Ethics programs have different focuses, there will be an element of overlap between the two processes.
A QAPI program aims to prevent “adverse events” in long-term care (LTC) facilities, while a Compliance and Ethics program aims to eliminate fraud, waste, and abuse.
A Compliance and Ethics program seeks to ensure the overall viability and best practice delivery for the facility while satisfying the requirements of the Centers for Medicare & Medicaid Services (CMS). QAPI has as its primary objective the maintenance of the best possible standard of care for residents. Both programs are ultimately aimed at providing the best possible care for LTC residents.
The Compliance and Ethics program’s focus on fraud, waste, and abuse is designed to prevent and detect criminal, civil, and administrative violations. This will promote quality of care and ensure that the resident receives the best possible service.
QAPI’s focus is on developing, implementing, and maintaining an effective, comprehensive, data-driven program. This will provide accurate summaries on outcomes of care and quality of life for the residents.
The nature of lapses which may be identified by either process will sometimes make it inevitable that the QAPI or the Compliance and Ethics program will impact each other.
This is especially so due to the Office of Inspector General’s (OIG) definition of fraud, waste, and abuse. The OIG counts the provision of subpar standards of service as fraud—because it means that government finances have been used to provide a service which did not exist, known as worthless care.
In other words, a preventable QAPI-related failing such as an excessive number of falls or pressure ulcers could be regarded as fraud by the OIG. In this way, a QAPI issue could quickly transform into a civil or criminal liability, and be placed firmly into the Compliance and Ethics field of operations. It is through the existence and effective implementation of both programs—QAPI and Compliance and Ethics—that an LTC can take the fullest possible measures to adhere to the legal and moral obligations of providing effective and high-
