In November 2023, the United States Health & Human Services Officer of Inspector General (“OIG”) issued new compliance program guidance for the healthcare industry, referred to as the General Compliance Program Guidance (“GCPG”). The OIG has provided detailed, nonbinding compliance program guidance (“CPGs”) for providers, including industry-specific guidance, since 1998. The new GCPG is part of the OIG’s modernization initiative and, according to the OIG, an effort to “produce user-friendly and accessible information and to promote greater flexibility to update CPGs as new areas emerge.”
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OIG’s new approach includes:
- Publishing CPGs on its website with new interactive links to resources and discontinuing publishing CPGs in the Federal Register;
- Issuing the GCPG applicable to all individuals/entities in the healthcare industry with industry segment-specific CPGs (“ICPGs”); and
- Providing the public and stakeholders with an opportunity to provide feedback on the GCPG and ICPGs via email by emailing compliance@oig.hhs.gov.
The GCPG is available now on the OIG’s website and provides an overview of key federal laws for healthcare providers, the seven elements of a compliance program, adaptations for small and large entities, other compliance considerations, and OIG processes and resources.
As of 2024, the OIG will be issuing ICGPs for different types of providers and suppliers intended to be tailored to their specific risk areas and detailing compliance measures they can take to reduce these risks.
The GCPG is a must-read for all healthcare compliance professionals. Although the OIG cautions that it is not intended to be a one-size-fits-all, completely comprehensive list of risks for every organization, it is a helpful tool for healthcare compliance professionals to use to evaluate their compliance policies and provides tips and recommendations from the OIG on implementation issues.
On our podcast this week, I talk more about the GCPG and share some of my insights from the new guidance.
