Publication

Get Access To The Right HHS OIG’S Compliance Program Guidance

Strategic Management Services, LLC | March 2015

The U.S. Department of Health and Human Services (HHS), Office of Inspector General (OIG) provides guidance to various healthcare providers in the form of compliance program guidance documents.[1] These documents provide insightful and useful information on how to structure an effective compliance program. In today’s enforcement environment, HHS is closely scrutinizing healthcare providers’ compliance programs. It is no longer sufficient to simply have a compliance program. HHS wants to see evidence that the program is effectively identifying fraud, waste, and abuse, that the program fosters an ethical environment for employees and that the organization is largely choosing to do the right thing.

The OIG drafted compliance program guidance documents for numerous types of healthcare providers.

As a helpful reference, included below are links to those guidance documents.

• Hospitals
  • Compliance Program Guidance for Hospitals (63 Fed. Reg. 8987; February 23, 1998) http://oig.hhs.gov/authorities/docs/cpghosp.pdf
  • Supplemental Compliance Program Guidance for Hospitals (70 Fed. Reg. 4858; January 31, 2005) http://oig.hhs.gov/fraud/docs/complianceguidance/012705HospSupplementalGuidance.pdf

• Nursing Facilities
  • Compliance Program Guidance for Nursing Facilities (65 Fed. Reg. 14289; March 16, 2000) http://www.oig.hhs.gov/authorities/docs/cpgnf.pdf
  • Supplemental Compliance Program Guidance for Nursing Facilities (73 Fed. Reg. 56832; September 30, 2008) http://oig.hhs.gov/compliance/compliance-guidance/docs/complianceguidance/nhg_fr.pdf

• Research Recipients
  • Draft Compliance Program Guidance for Recipients of PHS Research Awards (70 Fed. Reg. 71312; November 28, 2005) http://oig.hhs.gov/fraud/docs/complianceguidance/PHS%20Research%20Awards%20Draft%20CPG.pdf
  • NSTC Launches Government-Wide Initiative Based on OIG Draft Guidance for HHS Research Grants (June 7, 2006) http://oig.hhs.gov/publications/docs/press/2006/ResearchCPG-finalrelease06072006.pdf

• Pharmaceutical Manufacturers: Compliance Program Guidance for Pharmaceutical Manufacturers (68 Fed. Reg. 23731; May 5, 2003) http://oig.hhs.gov/authorities/docs/03/050503FRCPGPharmac.pdf

• Ambulance: Compliance Program Guidance for Ambulance Suppliers (68 Fed. Reg. 14245; March 24, 2003) http://oig.hhs.gov/fraud/docs/complianceguidance/032403ambulancecpgfr.pdf

• Physician Practices: Compliance Program Guidance for Individual and Small Group Physician Practices (65 Fed. Reg. 59434; October 5, 2000) http://oig.hhs.gov/authorities/docs/physician.pdf

• Medicare+Choice Organizations: Compliance Program Guidance for Medicare+Choice Organizations (64 Fed. Reg. 61893; November 15, 1999) http://oig.hhs.gov/fraud/docs/complianceguidance/111599.pdf

• Hospices: Compliance Program Guidance for Hospices (64 Fed. Reg. 54031; October 5, 1999) http://oig.hhs.gov/authorities/docs/hospicx.pdf

• DME: Compliance Program Guidance for the Durable Medical Equipment, Prosthetics, Orthotics, and Supply Industry (64 Fed. Reg. 36368; July 6, 1999) http://oig.hhs.gov/authorities/docs/frdme.pdf

• Third-Party Medical Billing Companies: Compliance Program Guidance for Third-Party Medical Billing Companies (63 Fed. Reg. 70138; December 18, 1998) http://oig.hhs.gov/fraud/docs/complianceguidance/thirdparty.pdf

• Clinical Laboratories: Compliance Program Guidance for Clinical Laboratories (63 Fed. Reg. 45076; August 24, 1998) http://oig.hhs.gov/authorities/docs/cpglab.pdf

Home Health Agencies: Compliance Program Guidance for Home Health Agencies (63 Fed. Reg. 42410; August 7, 1998) http://oig.hhs.gov/authorities/docs/cpghome.pdf

[1] Department of Health and Human Services Office of Inspector General. “Compliance Guidance.” <http://oig.hhs.gov/compliance/compliance-guidance/index.asp>