On April 24, at this year’s Compliance Institute, the U.S. Department of Health & Human Services (HHS) Inspector General (IG) Christi Grimm announced an important initiative, which was posted in the Federal Register the next day. The Compliance Program Guidance documents (CPGs) that provide valuable information (but are also getting up in age) will soon be updated and modernized. Much of the existing guidance—such as hospital compliance program guidance—is more than 20 years old. And while much of it still applies, and some of it was updated in the early 2000s, there are many areas of compliance that have emerged or evolved since then.
It was great news to hear the IG’s plans. A new format will also accompany the updated guidance. Rather than having all CPGs devoted solely to one segment of the broad healthcare sector, there will now be a general CPG that addresses topics common to any individual or organization in the healthcare sector, followed by industry-specific guidance (e.g., hospitals, nursing homes, etc.). This will avoid some of the repetition that would otherwise be necessary from one industry document to another. The general CPG is expected by the end of 2023, while the industry-specific CPGs will begin being published in 2024.
This is a huge effort for HHS Office of the Inspector General (OIG), as there is a lot of guidance to be modernized. And the initiative comes just a little more than a year after Christi Grimm received Senate confirmation as the next IG. What a great and very welcome initiative so early in her tenure as IG. Over the years, OIG has been a great partner to the compliance profession, actively seeking input from the profession. This latest initiative continues a practice of listening and responding to the needs of the healthcare compliance community and providing timely and useful guidance in a rapidly changing environment.
As I travel to other areas of the world and speak with compliance professionals working in different circumstances, it is not lost on me just how fortunate we are to be working in an environment in which government agencies are truly trying to partner with compliance professionals and strive to provide helpful guidance.
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