Lexology November 29, 2023
In Short
The Situation: On November 6, 2023, the Office of Inspector General (“OIG”) of the U.S. Department of Health and Human Services (“HHS”) released its “General Compliance Program Guidance” (“GCPG”). The GCPG provides guidance that is generally applicable to “all individuals and entities” in the health care industry, from providers to manufacturers, suppliers, and investors.
The Action: While much of the GCPG is a consolidation of familiar guidelines and principles, OIG also recommends adding topics, such as quality and patient safety, to compliance reviews and expressly considers the impact of ownership and payment incentives on patient care. Like all HHS-OIG compliance documents, the GCPG is not binding on any individual or entity.
Looking Ahead: The GCPG is the first...
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