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...

Within the specific element discussions in HHS-OIG’s Guidance, are important operational details and strategies for an effective compliance program.  GCPG provides important suggestions and innovations for consideration by all compliance professionals. Effective Lines of Communication The GCPG stresses the importance of an open line of communication between the compliance officer and entity personnel as a means to reduce potential fraud, waste and abuse.  To this...