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Vermont Civil Money Penalty (CMP) Programs

Vermont’s Long Term Care Grant Program


A Civil Money Penalty is the monetary penalty the Centers for Medicare & Medicaid Services (CMS) may impose against CMS Certified Nursing Facilities (SNF/NF’s) for either the number of days or for each instance a facility is not in substantial compliance with one or more Medicare and/or Medicaid participation requirements for Long-Term Care Facilities.

Previously Funded Centers for Medicare Civil Money Penalty Projects
To view previously funded Civil Money Penalty (CMP) projects, please follow the link below to download the available informational files.
State CMP Reinvestment Projects Funded by CY Year.


The goal of the Vermont Civil Money Penalty Grant Program is to facilitate the use of federally imposed civil money penalty funds to support activities that support, protect and benefit residents living in CMS certified nursing homes.

These initiatives should showcase a variety of enhancement or educational philosophies through current and sound evidence-based practices that promote quality of care and quality of life for nursing facility residents.


The CMP grant program will accept applications from a licensed Vermont Nursing Facility or Nursing Facility Chain, or an outside entity collaborating directly with one or more Nursing Facility. Successful applicants must have demonstrated experience and expertise in promoting quality of care and/or quality of life for residents of nursing facilities, which also meet the requirements under this grant opportunity.

Project Categories

Direct Improvement to Quality-of-Care

CMP funds may be used for projects designed to directly improve care processes for nursing home residents in a single Nursing Facility or a Nursing Facility chain.

Resident or Family Councils

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

*Assist in the development of new independent family councils.

*Assist resident and family councils in effective advocacy on their family members’ behalf; and develop materials and training sessions for resident and family councils on state implementation of new federal or state legislation. For example, CMP funds could be used to support facilitators, involvement of knowledgeable experts in council meetings, or other initiatives to engage residents and families in the development and implementation of quality improvement programs.

Culture Change, Quality of Life

“Culture change” is the common name given to the national movement for the transformation of adult and older adult services, based on person-directed values and practices where the voices of consumers and those working with them are considered and respected.  Core person-directed values are choice, dignity, respect, self-determination and purposeful living.   CMP funds may be used to promote culture change in projects that involve a single Nursing Facility or a Nursing Facility Chain.

Consumer Information

CMP funds may be used to develop and disseminate information 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.


CMP funds may be considered for training in facility improvement initiatives that are open to a single Nursing Facility or a Nursing Facility chain, including joint training of facility staff and surveyors, technical assistance for facilities implementing quality assurance programs, training for resident and/or family councils, Long Term Care Ombudsman or advocacy organizations, and other activities approved by CMS. For example, CMS previously approved the use of CMP funds for a statewide pressure ulcer and fall prevention collaborative that included joint training of surveyors and facility staff from multiple nursing homes.

Availability of Funds

At the beginning of each state fiscal year, the Department of Aging and Independent Living shall determine the total amount of money to be allocated for the civil money penalty fund to be awarded in the form of grants to eligible entities.  There is no entitlement to any funds available for grants awarded through this initiative.   may award grants to the extent funds are available and within its discretion to the extent that applications are approved. Collaboratively, representatives from DAIL shall assess the merit of each proposed project and the ability of the project to improve resident outcomes and advance the care and services provided in certified long term care facilities.  Following this collaborative review, the selected CMP application/s will be forwarded to CMS for final approval.

Guidelines for Applicants

Eligible entities wishing to apply for CMP grants must meet the following requirements:

  1. Grants are available for quality improvement initiatives that are outside the scope of normal operations for the nursing facility or other applicant.
  2. Grants cannot be used as replacement funding for goods or services that the applicant already offers.
  3. When CMP funds are requested for educational purposes, the organization involved must also include the following:
  • Anticipated number of attendees.
  • Target audience.
  • Accrediting authorities.
  • Timeline for implementation and plan of sustainability.
  • And letters of support from nursing homes targeted for the project.

An applicant previously awarded a CMP grant that failed to achieve that initiative’s intended goals or outcomes shall be ineligible to apply for a period of 3 years following that grant award.  However, a grant may be considered if the applicant’s inability to complete the initiative was due to circumstances beyond the applicant’s control. 

Representatives from any facility requesting funding, or representatives who are in situations where a conflict of interest exists, must disqualify themselves from making recommendations.

Applications will not be accepted via fax or hardcopy.

Applications shall include a cover letter addressed to Suzanne Leavitt.

The font for applications is Times New Roman, 12 point, and shall include the entity name, and page number on all documents.

Applications shall be limited to no more than 20 pages, including appendices and the actual CMP application form.

All sections of the application form shall be completed in its entirety with all required information, or the application will be denied.

Grant Awards are not available for the following:

  1. Conflict of interest.
  2. General operations or administrative salaries.
  3. Capital improvements to a nursing home or to build a nursing home.
  4. Facility maintenance activities intended to meet minimum standards.
  5. Goods or services for which the applicant or others are already obligated to pay.
  6. Vendor payments and payroll obligations for normal operations or for fulfillment of state or federal requirements.
  7. Salaries of temporary managers who are actively managing a nursing home.
  8. Costs related to travel, bonuses or other direct employee benefits.
  9. Costs that are not specifically outlined in the applicant’s grant purpose or are already included in the facility’s cost report.
  10. Projects, programs, goods or services unrelated to improving the quality of life or quality of care of NF residents.
  11. Recruitment or providing Long Term Care Ombudsman certification training for staff or volunteers, or investigation and work to resolve complaints.

Instructions for Downloading and Submitting the Application

  1. Complete Application:  Vermont Application For Use of CMP Funds.
  2. Submit completed application including all attachments to:

Review of Grant Applications

The CMP Grant Committee will collaboratively conduct an initial review and evaluate all components of the completed grant application.  Reviewed applications and the state’s recommendation for approval will be forwarded to CMS. All grant awards are subject to final approval by the CMS Regional Office.

Expectations for Application Categories

Purpose and Summary - Describe the project purpose and project summary.

Expected Outcomes – A description of the intended outcomes, deliverables and sustainability beyond the scope of the grant.

Results Measurements – A description of the methods by which the project result will be assessed, including specific measures.

Benefits to Nursing Home Residents – A Description of the manner in which the project will benefit nursing home residents.

Consumer, Staff, Stakeholder Involvement – A description of how the nursing home community (including the residents and/or family councils and direct care staff) will be involved in the development and implementation of the project.

Involved Organizations – List all organizations that will receive funds through this project, and organizations that will be responsible for this project including any suppliers/vendors.

Funding, Project Time-line – Provide a specific itemized budget of CMP funds to be used for this project.  Itemize all other funds that will contribute to the project. Provide a detailed project timeline including the expected project completion timeframe.

Non-Supplanting – A description of the manner in which the project will not supplant existing responsibilities of the nursing home to meet existing Medicare/Medicaid requirements or other statutory regulatory requirements.

Grant Awards

Grants for approved proposals shall be awarded through a contract entered by DAIL and the applicant. Grant Funds shall be distributed pursuant to contractual obligations.

Quarterly Progress Reports

Following the date of the award and continuing until completion, the grantee shall submit quarterly reports on the status of the project to: Awardees will receive additional instructions at the time of the grant agreement is signed. A grantee that fails to submit a quarterly progress report shall forfeit any future grant award distributions.  


Quarterly Reports — Quarterly reports must be submitted within 15 calendar days at the conclusion of the quarter for each three-month period throughout the identified project timeline.

Final Report – A final report of the project shall be submitted within 30 calendar days at the conclusion of the project.

The Grant Award Final Report must provide evidence of successful completion of the project or quality improvement initiative and address the following:

  • The purpose of the grant.
  • The expected outcomes.
  • The actual outcomes.
  • The number of residents that benefited from the project or initiative; and
  • The action plan for sustainability if the project or initiative will continue beyond the grant funding.
  • All reports should be submitted to