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November 7, 2023
Healthcare Update

OIG Issued Updated General Compliance Program Guidance for Healthcare Providers and Stakeholders

On Monday, November 6, 2023, the U.S. Department of Health and Human Services Office of Inspector General (“OIG”) released its General Compliance Program Guidance (“GCPG”) for the general healthcare compliance community and other healthcare stakeholders. The GCPG generally covers the following topics:

  • Overview of Various Federal Healthcare Laws, including the:
    • Anti-Kickback Statute
    • Physician Self-Referral Law
    • False Claims Act
    • Civil Monetary Penalty Authorities
    • Exclusion Authorities
    • Criminal Healthcare Fraud Statute
    • HIPAA Privacy and Security Rules
  • Seven Elements for a Compliance Program Infrastructure
    • Written Policies and Procedures
    • Compliance Leadership and Oversight
    • Training and Education
    • Effective Lines of Communication with the Compliance Officer and Disclosure Programs
    • Enforcing Standards
    • Risk Assessment, Auditing, and Monitoring
    • Responding to Detected Offenses and Developing Corrective Action Initiatives
  • Compliance Program Adaptations for Small and Large Entities
  • Other Compliance Considerations
  • OIG Resources and Processes

The GCPG can be accessed by following this link. Even though the GCPG is voluntary guidance for the healthcare industry, providers should review the GCPG and, as necessary, update their compliance plans. The OIG will publish industry-specific guidance in 2024, and our team will track and provide links once those resources are published.

This publication is designed to provide general information on pertinent legal topics. The statements made are provided for educational purposes only. They do not constitute legal or financial advice nor do they necessarily reflect the views of Holland & Hart LLP or any of its attorneys other than the author(s). This publication is not intended to create an attorney-client relationship between you and Holland & Hart LLP. Substantive changes in the law subsequent to the date of this publication might affect the analysis or commentary. Similarly, the analysis may differ depending on the jurisdiction or circumstances. If you have specific questions as to the application of the law to your activities, you should seek the advice of your legal counsel.


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