In November 2023, HHS-OIG issued a comprehensive document, the General Compliance Program Guidance (“GCPG”), which outlines important compliance guidance for the healthcare industry.

The GCPG provides specific guidance on compliance with the Federal anti-kickback statute (“AKS”), the Physician Self-Referral Law (“Stark Law”), the False Claims Act, HIPAA Privacy and Security, Exclusion Authorities, and Criminal Healthcare Fraud. Aside from this important compendium of statutory and regulatory requirements, the GCPG provides important compliance guidance, best practices and established strategies for compliance programs in the health care industry.

The GCPG is organized around the seven established elements of an effective compliance program.  While the healthcare industry includes a variety of service providers, ranging in size, and type of delivery service, the GCPG recognizes that specific program elements will vary, especially for smaller entities.  The GCPG incorporates HHS-OIG’s experience over 25 years, prior guidance, experience monitoring Corporate integrity Agreements (“CIAs”), industry stakeholder meetings, lessons learned from investigations and enforcement actions and the continuing innovation and evolution of healthcare delivery systems.

In this Episode. Michael Volkov reviews the HHS-OIG Guidance and the important compliance guidance strategies and best practices.