On November 6, 2023, the Department of Health and Human Services Office of Inspector General (OIG) issued General Compliance Program Guidance (GCPG) via publication on its website, which can be accessed by this link.

The GCPG is the first formal compliance guidance to be published by OIG in 15 years. Prior to this GCPG publication, OIG issued compliance program guidance via the Federal Register for select industries, occasionally issuing supplemental guidance, as well.

The newly issued GCPG is the “hub” of OIG’s new “hub and spoke” model for voluntary compliance guidance. OIG will be issuing Industry Compliance Program Guidance (ICPG) beginning in 2024 as the “spokes.” Until that time, industry stakeholders can continue to use the legacy OIG compliance guidance in conjunction with this new GCPG for reference guide resources.

Generally, the GCPG provides an outline of voluntary compliance guidance for the healthcare industry and focuses on the same seven elements of an effective compliance program that have been previously published and accepted in the industry. This GCPG is exclusively on the OIG website, as opposed to the federal register, and includes citations and hyperlinks throughout the 91-page PDF to authorities and references. 

Nelson Mullins’ experienced healthcare team will be publishing more on this topic soon.