On November 6, 2023, the Office of Inspector General (OIG) released new General Compliance Program Guidance (GCPG) for the healthcare community. The GCPG is voluntary guidance that discusses general compliance risks and compliance programs. OIG states that the guidance is not intended to serve as a model compliance program, but sets forth compliance guidelines and tips and to identify some risk areas that it believes individuals and entities engaged in the healthcare industry should consider when developing and implementing a new compliance program or evaluating an existing program.
The GCPG is organized into seven sections: an introduction, an overview of health care fraud enforcement and other standards, compliance program infrastructure (the seven elements), compliance program adaptations for small and large entities, other compliance considerations, OIG resources and processes, and a conclusion. You may access the GCPG here:
https://oig.hhs.gov/compliance/general-compliance-program-guidance/
If your organization is unclear why an OIG compliance program is mandatory for Medicare and Medicaid providers when the OIG guidance is voluntary, please refer to the article “Office of Inspector General Compliance Program” in the October 2023 Advisor® issue.
Note: Although the new OIG guidance is not binding, Eagle Associates will provide an update to its OIG Compliance Program in March 2024 to incorporate additional information from the guidance that will further help users to implement a successful fraud, waste and abuse prevention program.
