2023 OIG and DOJ Compliance Guidance for Healthcare Providers

This CLE webinar will guide counsel and compliance officers of healthcare providers and other stakeholders on both the U.S. Department of Health and Human Services Office of Inspector General's (OIG) and U.S. Department of Justice's Criminal Division's (DOJ) recent compliance guidance. The panel will discuss both the OIG's and the DOJ's approaches to compliance and the factors each considers to assess whether a compliance program is effective.

On Nov. 6, 2023, the OIG published its much-anticipated General Compliance Program Guidance (GCPG) as a voluntary guide to be used when creating healthcare compliance programs or when assessing existing healthcare compliance programs. This represents the first major update to OIG compliance program guidance since 2008 and applies to all individuals and entities in the healthcare industry.

While the GCPG is generally applicable to all healthcare providers, beginning in 2024, the OIG will publish industry-specific compliance program guidance (ICPG) for different types of providers, suppliers, and other participants, and anticipates issuing ICPGs first for managed care organizations and nursing facilities.

Earlier in 2023, the DOJ issued an updated version of its Evaluation of Corporate Compliance Programs, which serves as a guide for prosecutors to use when evaluating whether and to what extent healthcare providers have effective compliance programs. It is also a valuable tool to use when preparing or evaluating the effectiveness of a compliance program.

Listen as our authoritative panel of healthcare attorneys examines the GCPG for healthcare compliance. The panel will review the federal laws involved and the compliance program infrastructure. The panel will also discuss the DOJ's and OIG's approaches to enforcement and offer best practices for compliance.