Revisions to CMP Tool:
When noncompliance exists, enforcement remedies, such as civil money penalties (CMPs), are intended to promote a swift return to substantial compliance for a sustained period of time, preventing future noncompliance.

To increase national consistency in imposing CMPs, the Centers for Medicare & Medicaid Services (CMS) is revising the CMP analytic tool in the following areas which are further explained within this policy memorandum:
Past Noncompliance; Per Instance CMP is the Default for Noncompliance Existed Before the Survey; Per Day CMP is the Default for Noncompliance Existing During the Survey and Beyond;
Revisit Timing; and Review of High CMPs.

This policy memo replaces S&C Memo 15-16-NH: The prior versions of the CMP Tool are obsolete, as of the effective date of this memo, July 17, 2017