Civil Money Penalty (CMP) Reinvestment Program

Overview

A Civil Money Penalty (CMP) is a monetary penalty that the Centers for Medicare and Medicaid Services (CMS) may impose against Nursing Facilities for either the number of days or for each instance a nursing home is not in substantial compliance with one or more Medicare and Medicaid participation requirements for long-term care facilities (Code of Federal Regulations (CFR) [Title 42 Chapter IV. Subchapter G. Part 488 Subpart F. Section 488.430]). A portion of CMPs collected from nursing homes are returned to the states in which CMPs are imposed. CMP funds that are collected from Nursing Facilities in Louisiana are deposited into the Nursing Home Residents’ Trust Fund established by the Louisiana Legislature in accordance with the Omnibus Budget Reconciliation of 1987 (OBRA-87).

The CMP Reinvestment Program utilizes these funds to support projects that benefit nursing home residents and that protect or improve their quality of care or quality of life.

The CMP Reinvestment program was created as an effort to drive improvements in the quality of care for nursing home residents. The program aims to improve quality of life and care by equipping nursing home staff, administrators, and stakeholders with technical tools and assistance to enhance resident care.

CMP Reinvestment Project Categories

CMS has established a list of approvable CMP Project categories. Each of the project categories has a maximum funding amount to ensure the costs of the projects are reasonable.

Resident or Family Councils

CMP funds may be used for projects by not-for-profit resident advocacy organizations that:

Assist in the development of new independent family councils;
Assist resident and family councils in effective advocacy on their family member's behalf; and
Develop materials and training sessions for resident and family councils on state implementation of new federal or state legislation.

Consumer Information

CMP funds may be used to develop and disseminate information (e.g. flyers, brochures, booklets, web-based materials, etc.) that is directly useful to nursing home residents and their families in becoming knowledgeable about their rights, nursing home care processes and other information useful to a resident.

Training to Improve Quality of Care

CMP funds may be considered for training in facility improvement initiatives that are open to multiple nursing homes, including joint training of facility staff and surveyors, technical assistance for facilities implementing quality assurance programs, training for resident and/or family councils, LTC ombudsman or advocacy organizations and other activities approved by CMS. Training topics include, but are not limited
to:

Alzheimer's Disease & Dementia
Patient Safety
Cultural Change
Cultural Sensitivity
Trauma Centered Care
Pain Management
Person-Centered Care
Safe Medication Management
Non-Pharmaceutical Solutions
Falls Education
Oral Health
Wound Care

Activities to Improve Quality of Life

CMP funds can be used for projects to foster social interaction, movement, and minimize loneliness. Projects include, but are not limited to:

Gardening
Music Therapy
Animal Therapy (including robotic pets)
Activities and games fostering movement and function (This may include activities, group games, or technology assisted games.)
Reading and Memory Interventions
Crafting

For a more extensive list of allowable and non-allowable uses of CMP funds, click on one of the options below:

How to Apply

Proposal Submission

Interested applicants must download and fill out the CMP Reinvestment Project Proposal Summary. Once the form is completed, click “SUBMIT PROPOSAL” in the top right corner of the form and it will be sent via email to HSS-CMP-Fund@LA.gov.

Remember to attach a detailed budget and any additional documents when submitting the proposal summary. LDH - Office of Aging and Adult Services will perform an initial review of the proposed project summary and documentation.

Louisiana CMP Reinvestment Program Approval Process

CMP Reinvestment Project applications are subject to a series of approval steps. Additional information may be requested from the CMP Project applicant during each step of the approval process. The approval steps include the LDH and OAAS Leadership Review and the CMS Civil Money Reinvestment Project Determination. Click below for more information on these steps.

LDH & OAAS Leadership Review

LDH Leadership will collaboratively assess the merit of each project proposal that is received. Proposals are considered in terms of their relevance to LDH priorities and the budget constraints in place at the time of the proposal submission.

CMS Civil Money Reinvestment Project

LDH will submit the application to CMS. CMS will review all applications for completeness and reasonableness as well as to ensure that non-allowable expenses are not included.

If deficiencies or missing information is identified on the application, please refer to the CMP Application FAQs or the CMP Application Guide.
If a CMP Project is approved by CMS, the applicant will need to enter into a type of contract called a Cooperative Endeavor Agreement (CEA) with the Offie of Aging and Adult Services (OAAS), unless otherwise noted.

CMS-CMP Reinvestment Application

Common Application Errors

Lacks quantifiable target goals or objectives to measure the project against. Clear targets are necessary to evaluate the requested use of CMP funds and determine whether the project was successful.
Travel expenses are not broken down or aligned with generally accepted rates such as those of the State or Federal Government.
Budget is not itemized.
No evidence that nursing homes are requesting the training/project and are committed to participating, such as letter(s) of support (non-nursing home applicants). Without this evidence, there is no guarantee that residents will directly benefit from the requested use of CMP funds.

Additional CMP Project Information and Guidance

CMS - CMP Reinvestment Program

Reference Documents

Nursing Facility Resources and Trainings

For more info, contact:

LDH Office of Aging and Adult Services
Baton Rouge, LA 70821
Phone: 225-432-0099
Email: HSS-CMP-Fund@la.gov