Office of Inspector General (OIG) released their new General Compliance Program Guidance (GCPG) today and it is a must-read for all healthcare compliance professionals.
The document outlines new, extensive, expectations for corporate compliance programs. The 91 page document contains numerous “tips”, regulatory citations and links to additional resources.
The OIG will be publishing additional, industry, segment specific guidance in 2024.
The new guidance addresses many topics including:
- Healthcare fraud enforcement
- Compliance with Federal laws such as:
- Stark
- Anti-kickback
- HIPAA
- Information blocking
- False claims act
- 7-elements of an effective compliance program with heightened expectations in all areas including, but not limited to:
- Oversight
- Financial incentives
- Auditing and monitoring
- Compliance committee and board responsibilities
- Additional considerations for both small and large entities
Although the document is framed as “guidance” and “voluntary”, it is clear the guidance outlines the standards to which an organization will be held. Additionally, the guidance is consistent in many regards with prior DOJ and OIG guidance pertaining to the evaluation of compliance program effectiveness.
Many compliance departments are already understaffed and do not have sufficient budgets. Organizations are going to need to carefully evaluate their programs, staffing qualifications, resources, and budgets in light of this newest guidance.
The new guidance is located here: https://oig.hhs.gov/compliance/general-compliance-program-guidance/
