Lexology November 14, 2023
On Nov. 6, the Department of Health and Human Services Office of Inspector General (OIG) released a document entitled “General Compliance Program Guidance” (GCPC or the Guidance), the first new compliance guidance the OIG has released in 15 years.
Prior to the release of the Guidance, the OIG promulgated compliance guidance for specific industry sectors (e.g., physician practices, hospitals, etc.) and other organization types (e.g., research grant recipients). In addition, during the intervening years since the OIG’s most recent industry-specific guidance, additional details and information were released via Federal Register issuances, Advisory Opinions, and Special Fraud Alerts, as well as other less formal means. The Guidance is the OIG’s attempt to unify the structure and function of compliance programs across...
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