In reading this further directly from the ACA as written and published in final draft, the MARCH 2013 deadline (3/23/2013) is specific to Skilled nursing facilities.. it does go on to say the mandatory required components of a compliance and ethics program date will be determined by March of 2013. Sorry everyone. I've always required my providers / clients to have a compliance plan, policies/procedures and other important things regardless of it now being mandatory so this really wasn't a big deal for me, plus I have no more clients that par with Medicare or Medicaid at all anymore. I still require them to have one though to address important compliance issues.