Manatt Health November 16, 2023
The Big Picture
Many health care stakeholders have long relied on the U.S. Department of Health and Human Services (HHS) Office of Inspector General (OIG) guidance regarding an effective compliance program when developing their own compliance programs, especially when contracts and less prescriptive federal and state laws mandate that such stakeholders have a compliance program. Even those stakeholders not technically required to have a compliance program often adopt them, as they are seen as a standard and best practice.
On November 6, the OIG released its General Compliance Program Guidance (GCPG), a generally applicable reference guide for health care industry stakeholders to use in building, implementing and evaluating their compliance programs;1 the GCPG represents the OIG’s first comprehensive update to...
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