General Compliance Program Guidance

The OIG has published Model Compliance Guidance over the years and in some cases has updated them. This is not the case for the guidances both to small physician practices or billing agents. Those have not been updated it more than twenty years. The risk areas they identify are not complete given the inexorable enforcement by the OIG in the years since. In late 2023, the OIG published an entirely new document, General Compliance Program Guidance, which is not limited to any specific sector of the health care industry. It is actually a useful document to provide guidance to physician groups and billing companies to update existing compliance programs. Maintaining a compliance program is still voluntary for these sectors, but to not have one in this day and age is just foolhardy. A good plan and program are dynamic and change over time. We recommend (1) reviewing this OIG document which does not have to be read in detail to draw value from it; and (2) revisiting the vitality of your compliance program.