Private Investors and Digital Health Attracting OIG Attention: General Compliance Program Guidance to Watch

Lexology December 18, 2023
McDermott Will & Emery

On November 6, 2023, the US Department of Health and Human Services (HHS) Office of Inspector General (OIG) published the General Compliance Program Guidance (GCPG) as a revised reference guide for the healthcare compliance community and other healthcare stakeholders. As noted in our previous On the Subject, the GCPG is part of the ongoing OIG modernization initiative and, like previous compliance program guidance, is nonbinding, voluntary guidance. Nonetheless, OIG guidance has a significant influence on how compliance programs and efforts are designed and implemented.

Importantly, the GCPG specifically references technology companies as “new entrants to the healthcare sector” and notes “[t]he growing prominence of private equity and other forms of private investment” in the sector. Digital health companies and digital...

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