OIG Publishes General Compliance Program Guidance for the Health Care Industry

According to an advisory from law firm Arnold & Porter, on November 6, the Department of Health and Human Services Office of Inspector General (OIG) released a “General Compliance Program Guidance” (GCPG). This GCPG draws from numerous existing sources of OIG guidance and reiterates key OIG positions found in the 2003 Compliance Program Guidance for Pharmaceutical Manufacturers, the original four 1998 Compliance Program Guidelines (CPGs), various special fraud alerts, and other guidance documents. The publication follows OIG’s April 2023 announcement for plans to improve and update compliance program guidance more generally.

As with other OIG guidance documents, while the recommendations in the GCPG are a valuable source of insight into the agency’s current enforcement approach, they are not legally binding on the various industries within the scope of OIG’s jurisdiction, Arnold & Porter notes. Much of the content is not new, but there are a few areas worth noting for legal and compliance professionals in the health care and life sciences industries. 

Read the full advisory here.