Lexology July 28, 2025
BRG

Nursing facilities: How closely are you monitoring high-risk areas outlined by OIG?

On November 20, 2024, the Department of Health and Human Services Office of Inspector General (OIG) published an updated Industry Segment-Specific Compliance Program Guidance (ICPG) document for nursing facilities. OIG tailored the ICPG to risk areas specific to the nursing facility industry segment and recommended compliance measures that facility operators can take to reduce risks. OIG broke down the four broad sections of risks into Quality of Care and Quality of Life; Medicare and Medicaid Billing Requirements; Federal Anti-Kickback Statute; and Other Risk Areas.

This article addresses the final category, Other Risk Areas, which contains OIG’s recommendations for discrete risks including:

  1. Related-party transactions;
  2. Physician Self-Referral Law;
  3. Anti-supplementation;
  4. ...

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