Lexology January 8, 2024
U.S. Department of Health and Human Services (“HHS”), Office of Inspector General (“OIG”) recently published its General Compliance Program Guidance (the “GCPG”),1 non-binding guidance designed to assist health care industry participants in monitoring compliance with applicable health care statutes, regulations, and program requirements. The GCPG was published to the HHS-OIG website as part of HHS-OIG’s Modernization Initiative,2 and aggregates into a single document the advice of past Compliance Program Guidances (“CPGs”) issued between 1998 and 2008.3
While OIG’s guidance is largely familiar, the GCPG reflects several additions and clarifications, including (i) topics not addressed previously in past CPGs, including Information Blocking, cybersecurity, and quality and patient safety; (ii) new recommendations for previous topics, such as policy accessibility, compliance officer roles,...
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