Lexology November 9, 2023
The U.S. Department of Health and Human Services Office of Inspector General (HHS-OIG) earlier this week released General Compliance Program Guidance (GCPG) applicable to all individuals and entities involved in the healthcare industry. As discussed in a prior Sidley Update, the GCPG is the first in a series of voluntary, nonbinding compliance program guidances (CPGs) that HHS-OIG intends to publish in response to stakeholder feedback. The GCPG does not break new ground; instead, it reflects a compilation of previous guidance provided in various contexts by HHS-OIG regarding its perspective on the relevant fraud and abuse laws and the elements of effective compliance programs. Notably, the GCPG again spotlights HHS-OIG’s focus on manufacturer-sponsored speaker programs. It also addresses compliance considerations for...
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