On November 6, 2023, the OIG released its New General Compliance Program Guidance (GCPG). The GCPG is intended to serve as a voluntary reference guide for the health care compliance community and other healthcare stakeholders discussing general compliance risks and compliance programs. The GCPG addresses applicable federal healthcare laws, the “seven elements” of a compliance program, adaptions for small and large entities, and other compliance considerations. This is off the heels of the DOJ’s updated guidance issued in March 2023 regarding the DOJ’s Evaluation of Corporate Compliance Programs. Further, the OIG announced its intent to publish industry-specific Compliance Program Guidance.
All healthcare providers are required to have a corporate compliance program that is adequate and effective based on the size and scope of the organization. Providers should evaluate their existing corporate compliance programs as it is clear that these are coming under increased scrutiny by the OIG and DOJ – especially where there is a compliance issue under investigation by an auditing agency.
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