Lexology December 20, 2023
An updated compliance program guidance (the Guidance) has been published by the U.S. Department of Health and Human Services Office of Inspector General (OIG) in an effort to provide a framework and other useful information to bolster the compliance programs of healthcare providers, including new entrants like IT companies. Unlike the previous iterations, the updated, user-friendly Guidance is published on the OIG website and is anticipated to be updated with greater frequency.
Addressing the expansion of participants providing or supporting healthcare, OIG specifically states that such “new entrants” in the healthcare industry, such as technology companies, investors, and those providing nontraditional services such as care coordination services, are required to have a compliance plan in place. These “new entrants” are...