On November 6, 2023, the Office of Inspector General (OIG) overhauled its General Compliance Program Guidance (GCPG) after many years. This long-awaited resource is already making a big splash in the health care compliance community.
There are two ways to think about the GCPG. On one hand, it represents a comprehensive reference guide for health care teams that provides crucial insights on federal laws and compliance program infrastructure and policies.
Believe it or not, the newly released version of this document is a big deal. It incorporates feedback from different industry stakeholders that was received during the agency’s recent modernization initiative. And while the OIG notes that the document is not a “one size fits all” approach or “completely comprehensive of compliance considerations,” it still provides the necessary building blocks for organizations to reduce their risk in 2024 and beyond.
The reality is, health care fraud is occurring at a record rate. In fact, False Claims Act settlements and judgments alone exceeded $2B in 2022. But what can hospital teams proactively do to protect their organization and themselves from compliance risk? That’s what the GCPG is for, and while it’s not binding guidance on any individual or entity, the new version is still a fantastic, must-read resource.
Here are my key takeaways from the updated GCPG as it relates to hospital-physician relationships. I hope it helps!
The recently launched GCPC is an excellent resource for hospital compliance teams, especially as it relates to your physician relationships. The OIG’s new guidance on automating financial arrangements represents a fresh and modern approach from this agency, benefiting both hospitals and physicians by minimizing errors and compliance risks (for organizations and physicians alike). If you haven’t had the opportunity to read it yet, I highly recommend doing so. Even though it’s not mandatory, it provides essential building blocks (and good reminders!) that everyone should consider in their overall compliance strategy.