On November 6, 2023, the U.S. Department of Health and Human Services, Office of Inspector General (OIG) released its General Compliance Program Guidance (GCPG), the first in a series of new, non-binding reference guides designed to share information with health care compliance professionals and other health care industry stakeholders about relevant Federal laws, compliance program infrastructure, OIG resources, and other information useful to understanding health care compliance.
The GCPC will help all individuals and entities involved in the health care industry, including but not limited to physicians and hospitals, home health agencies and hospices, durable medical equipment (DME) suppliers, nursing facilities, Medicare Advantage Organizations (MAOs), and third-party medical billing companies to self-monitor compliance with applicable Federal laws and program requirements as part of their efforts to prevent, detect, and address fraud, waste, and abuse in the health care system.
This reference guide addresses the following topics and includes other tips and best practices on (1) key Federal authorities for those involved in the business of health care; (2) the seven elements of an effective compliance program; (3) compliance-related adaptations for small and large entities; (4) challenges that technology companies and other new industry entrants face; and (5) important information about financial incentives and tracking financial arrangements. Finally, the GCPG includes hyperlinks to and information about the numerous compliance and legal resources available on OIG’s website.
Given OIG’s longstanding commitment to supporting voluntary compliance efforts, it will also release industry-specific compliance program reference guides beginning in 2024. These forthcoming reference guides will include tailored information about fraud and abuse risk areas for different types of providers and suppliers, as well as measures they can take to reduce their respective risks. OIG will post all current, updated, and new reference guides (complete with interactive links to resources) at https://oig.hhs.gov/ to make these materials more user-friendly and accessible.
Should you have any questions regarding the above, please contact the authors, the Garfunkel Wild attorney with whom you regularly work, or contact us at [email protected].