The US Department of Health and Human Services Office of Inspector General (OIG) issued its new General Compliance Program Guidance (GCPG) on November 6, 2023.[1] The GCPG is an excellent resource for the healthcare provider looking to implement a compliance program, or compare their existing program with OIG’s most recent guidance.

The GCPG addresses applicable federal laws (including the Anti-Kickback Statute, Stark Law, False Claims Act, and HIPAA), the “seven elements” of an effective compliance program and other compliance considerations, and helpful OIG resources, such as Advisory Opinions and Special Fraud Alerts, among other topics. The GCPG is non-binding, voluntary guidance that discusses compliance risks and effective compliance program infrastructures.

For the seasoned compliance executive, there are really no surprises. However, given that this is the first compliance program guidance OIG has issued in over a decade, it is worth reviewing to ensure your organization’s compliance program “measures up.”

For more information, or assistance with your Compliance program, please do not hesitate to contact any member of our Senior Living Practice Group.

[1] https://oig.hhs.gov/documents/compliance-guidance/1135/HHS-OIG-GCPG-2023.pdf

Any information included here or through our website is presented solely for general informational purposes and is not in any way intended as legal advice, is not a substitute for getting actual legal advice from an attorney, and should not be acted upon as legal advice without first seeking qualified professional counsel specific to your needs and situation. Additionally, by providing this general information and the information on our website, no attorney client relationship is created.

by: John Paul Hessburg, Michael B. Kern, and Will Duffield

OIG Publishes November 2023 General Compliance Program Guidance

Key Contacts

Related Services