Lexology December 18, 2023
Crowell & Moring LLP

The Office of the Inspector General (OIG) of the U.S. Department of Health and Human Services (HHS) published the General Compliance Program Guidance (GCPG) on November 6, 2023. The GCPG provides updated descriptions of the seven elements of an effective compliance program that health care entities have long relied upon. The new guidance also includes recommendations to conduct annual internal risk assessments, to consider quality of care as a component of the compliance program, and to emphasize the importance of a board’s and executive leadership’s oversight of compliance.

Starting in 2024, OIG will publish industry segment-specific compliance program guidance (ICPGs) for different types of providers, suppliers, and other participants in health care industry subsectors. OIG emphasized that the purpose of...

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