75+
Skilled nursing facilities served
42 CFR § 483.85 · F-TAG F895 — Compliance and Ethics Program
A compliance program that actually runs — not a binder on a shelf.
SNF Compliance Services builds and operates compliance and ethics programs for skilled nursing facilities: the written program, the hotline, the reporting, and the ongoing review that federal Requirements of Participation demand.
Since 2021
Programs directed by experienced compliance professionals
Multi-state
Serving operators and management groups across the country
Services
Everything the regulation requires, handled end to end.
A full-service compliance company serving the skilled nursing facility industry since 2021 — the support structure behind your compliance program, built to meet the Requirements of Participation under F-Tag F895.
01 / PROGRAM & MANUALS
Compliance & Ethics Manual
A Compliance and Ethics Manual for all employees, contractors, and volunteers of the facilities — with relevant compliance guidance specific to your states of operation — built to meet the Requirements of Participation under F-Tag F895 and the June 2022 CMS guidance.
▸ IN PRACTICE
Printed manuals delivered facility-by-facility and kept current as regulations and your portfolio change.
02 / HOTLINE & PORTAL
Toll-free hotline & reporting website
A toll-free hotline and reporting website for compliance and ethics concerns — including fully anonymous reports — with facility posters displaying the hotline and website information to raise awareness of the program among staff.
▸ IN PRACTICE
Every report is logged, acknowledged, and tracked through resolution. Staff can call 1-877-763-4685 (1-877-SNF-HOTL) or file any time at the Ethics & Compliance Reporting Portal.
03 / TRAINING
Staff training & annual Train-the-Trainer
Training materials, including a ready-to-present slide deck, for appointed personnel at each facility to educate staff and new hires on the Compliance and Ethics Program — plus annual Train-the-Trainer instructional sessions for the staff members overseeing the program, covering proper implementation and successful operation.
▸ IN PRACTICE
Your people deliver the training with our materials — building the program into orientation and annual education.
04 / MONTHLY CALLS & REPORTING
Monthly compliance calls & summaries
Monthly phone calls with appointed personnel at each facility to ensure compliance issues are being addressed properly and to work through issues as they arise — followed by a written summary of all monthly compliance calls identifying high-risk areas for facilities to address.
▸ RED-FLAG REVIEW
High-risk items are flagged in red and surfaced to leadership — not buried in an appendix.
05 / ANNUAL REVIEW
Annual program review
An annual review of each facility's Compliance and Ethics Program, as required by the Requirements of Participation under F-Tag F895 — documented, with revisions implemented so the program reflects current law and your operations.
▸ IN PRACTICE
The review that proves the program is operating — the first thing a surveyor asks for.
The Program
Built on the seven elements of an effective compliance program.
Federal guidance for nursing facilities is organized around seven required components. Our engagement covers each one — by design, not by accident.
ELEMENT 1
Written standards, policies & procedures
Facility-specific standards of conduct and compliance policies, maintained in current printed and electronic form.
ELEMENT 2
Compliance oversight & designated leadership
A designated compliance officer and contact structure with sufficient authority and direct access to governance.
ELEMENT 3
Training & education
Effective communication of standards to all staff, contractors, and volunteers — documented and repeated.
ELEMENT 4
Anonymous reporting & non-retaliation
A hotline and portal staff can actually use, with a written non-retaliation policy behind it.
ELEMENT 5
Monitoring & auditing
Reasonable steps to detect issues: log review, report tracking, and periodic compliance summaries to leadership.
ELEMENT 6
Enforcement & discipline
Consistent, documented standards enforced through appropriate disciplinary mechanisms.
ELEMENT 7
Response & prevention
Prompt, documented response to detected issues — and program revisions that keep them from recurring.
BASIS: 42 CFR § 483.85 · U.S. SENTENCING GUIDELINES § 8B2.1 · OIG COMPLIANCE PROGRAM GUIDANCE FOR NURSING FACILITIES
About
Built with regulatory rigor.
Compliance in a skilled nursing facility isn't paperwork — it's a condition of participation in Medicare and Medicaid, and it's the first thing surveyors and auditors ask about when something goes wrong.
SNF Compliance Services was founded in 2021 and is directed by an attorney, and it shows in how the work is done: programs built the way the regulation is actually written, documentation that holds up under scrutiny, and reporting structured for surveyor review.
SNF Compliance Services is a consulting firm. Its services are not intended to constitute the practice of law, and engaging the firm does not create an attorney–client relationship.
What we provide is the running program: the manuals, the hotline, the reporting, and the annual review.
We serve owners, operators, and management companies — from single facilities to multi-state portfolios — and we stay with the program through growth, sales, and transitions.
Founder & Compliance Coordinator
Maury Herzberg, JD
A graduate of Brooklyn Law School and an attorney admitted in New York and New Jersey, Maury Herzberg founded SNF Compliance Services LLC and has built and operated compliance and ethics programs for more than 75 skilled nursing facilities. He leads a team directing program development, reporting, and hotline operations for the firm's clients.
Note: all engagements are in a consulting capacity, not as legal counsel.
mh@snfcs.com
T 212.457.8989
T 212.457.8989
Common Questions
Is your facility actually required to have this?
Is a compliance and ethics program legally required?
Yes. Under the Phase 3 Requirements of Participation, every facility participating in Medicare or Medicaid must operate a compliance and ethics program meeting the components of 42 CFR § 483.85. CMS added F-Tag F895 (Compliance and Ethics Program) to surveyor guidance in June 2022, and it is a condition of participation — not a best practice.
What happens if we don't have one — or it only exists on paper?
Surveyors can cite the facility directly under F-Tag F895, and deficiencies carry the usual consequences: plans of correction, civil money penalties, and in serious cases jeopardy to Medicare and Medicaid participation.
Just as important, the regulation requires a program that is operating effectively. A binder that no one has opened since the last survey fails that test — and it fails it visibly, in front of surveyors, auditors, and plaintiffs' counsel.
Why outsource instead of handling it in-house?
Because a working program is an operation, not a document: printed manuals in every building, a staffed reporting channel, tracked acknowledgments, periodic summaries to leadership, and an annual review. Most facilities don't have the staff to run that — and hiring for it costs far more than engaging a firm that already has the infrastructure built and running across dozens of facilities.
Who should serve as our compliance officer?
One of your own principals or senior leaders. For operating organizations with five or more facilities, § 483.85(d) requires a designated compliance officer whose major responsibility is compliance, who reports directly to the governing body — and who may not be subordinate to the general counsel, chief financial officer, or chief operating officer.
We support that officer. The written program, the hotline, the tracked reports, the board-ready summaries, and the annual review documentation — your officer holds the role, and we do the work behind it.
What does getting started look like?
We assess what exists today, deliver facility-specific manuals and policies, stand up the hotline and reporting portal, and establish the reporting cadence to leadership. For operators taking over facilities in a transaction, the program transfers with the buildings — new ownership inherits a running program on day one.
Contact
Put your compliance program in order.
Whether you're standing up a program for the first time, taking over facilities in a transition, or replacing a program that exists only on paper — start with a conversation.
- mh@snfcs.com
- Phone
- (212) 457-8989