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not-for-profit may solicit and accept donations unrelated to the care of a specific resident.

The LTC facility guidance allows a great deal of latitude in design and operations, and a compliance program can and should be customized to fit the size, resources, and risks of the organization. Neither guidance statements are intended to represent complete "compliance plans;" both are a starting point. The seven standard OIG recommendations for compliance plans form a starting outline: " Designation of a compliance of> ficer and compliance committee " Development of compliance > policies and procedures, including standards of conduct ° Developing open lines of communications ° Appropriate training and teaching o Internal monitoring and auditing " Response to detected deficiencies ° Enforcement of disciplinary standards Effective plans are not derived from "cookbook" sources or written and left on a shelf. There is plenty of work ahead for many facilities. Ul

Tom Eaiey, iVIA, an associate professor of business administration at Alma College, has three decades of experience with long-term care as a CPA, consultant, seminar leader, and writer. For more information, visit www.alma. edu/people/faculty/list/îfaculty^ealey. Marcy Gilstad, a candidate for a Bachelor of Arts at Alma College, is a member of the Phi Beta Kappa scholars honorary and will attend graduate school studying healthcare administration.

Disclaimer: Legal advice should always be obtained from licensed and experienced legal counsel.

32 • APRIL 2011

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