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Senior Living Liability

Skilled nursing

Does insurance pay CMS civil money penalties?

Generally no. Civil money penalties are typically treated as uninsurable on the same public policy reasoning that applies to punitive damages: an insurer paying the penalty would defeat the deterrent purpose the penalty exists to serve.

What is insurable is the defense. Regulatory and survey defense coverage pays the legal and consultant cost of responding to a survey deficiency, an immediate jeopardy finding or a licensure action.

The term that decides whether that grant helps is when it triggers. The expensive work happens in the days after the exit conference and through the plan of correction process, before anything that looks like a formal administrative proceeding exists. A grant that responds only on a formal proceeding arrives after most of the money is spent.

Source: CMS, 42 CFR Part 483

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