Creating a playbook to implement OIG’s new General Compliance Program Guidance

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In November, the U.S. Department of Health and Human Services Office of Inspector General (OIG) issued its General Compliance Program Guidance (GCPG). This guidance serves as an essential resource for professionals and organizational decision-makers. Astute compliance professionals will craft strategies grounded in the GCPG. This involves fully grasping the content and implications of the GCPG, promoting internal dialogue regarding its application, and identifying and implementing practices that leverage its insights for enhancing compliance program effectiveness.

The GCPG—extending over 91 pages—contains a trove of information. Given its extensiveness, this article focuses on some of OIG’s most compelling statements relating to compliance program infrastructure. They are found in Section III of the GCPG, Compliance Program Infrastructure: The Seven Elements.[1]

The entire document is required reading for those aspiring to cultivate best practices in their compliance programs because:

  • OIG’s guidance has traditionally become a standard for expected industry practices. The GCPG, as OIG’s most extensive compliance program guidance in 25 years, is poised to reinforce and reset industry standards.

  • The GCPG tackles significant challenges faced by compliance professionals and their organizations, including issues related to reporting structures, empowerment, and governance by boards.

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