General Compliance Program Guidance

Lexology November 22, 2023
Akerman LLP

The Office of Inspector General of the U.S. Department of Health and Human Services (the OIG) recently released an updated document (GCPG). The GCPG has been anticipated since the OIG announced on April 25, 2023, that it planned to modernize the accessibility and usability of its publicly available resources, including the OIG’s Compliance Program Guidance (CPG) documents. We recommend that the healthcare compliance community and other healthcare stakeholders review the GCPG carefully, and, in particular, that all healthcare compliance officers ensure they use the GCPG as a guidebook going forward.

The OIG has been releasing voluntary,nonbinding CPG documents since 1998 “to encourage the development and use of internal controls to monitor adherence to applicable statutes, regulations, and program requirements.” The...

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