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OIG’s New Compliance Guidance: 10 Action Items and Six Themes for Providers

By Holly Buckley, Timothy Fry, Kimberly J. Kannensohn, Anna Timmerman & Kristen H. Chang on January 11, 2024
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On Nov. 6, 2023, the U.S. Department of Health and Human Services Office of Inspector General (OIG) issued its General Compliance Program Guidance for healthcare providers and other industry stakeholders. The guidance follows OIG’s previous announcement about a modernization initiative and signifies a major update to OIG’s prior approach to providing guidance on effective compliance programs.

Read on for actionable steps healthcare providers should consider implementing in 2024, as well as key themes derived from the OIG document that should guide compliance efforts.

Photo of Holly Buckley Holly Buckley

A national leader in healthcare M&A, private equity and finance transactions, Holly chairs McGuireWoods’ Healthcare Department, one of the largest healthcare practices in the United States. PE funds and healthcare clients — including hospitals, health systems, medical practices, physician-owned hospitals and ambulatory surgery…

A national leader in healthcare M&A, private equity and finance transactions, Holly chairs McGuireWoods’ Healthcare Department, one of the largest healthcare practices in the United States. PE funds and healthcare clients — including hospitals, health systems, medical practices, physician-owned hospitals and ambulatory surgery centers, among others — rely on her for structuring transactions, regulatory due diligence, affiliation agreements and compliance matters.

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Photo of Timothy Fry Timothy Fry

Tim resolves clients’ thorny compliance and regulatory issues that make or break healthcare transactions and operations. He delivers practical, business-oriented solutions that clear obstacles, close deals, and protect enterprise value.

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Photo of Kimberly J. Kannensohn Kimberly J. Kannensohn

Kimberly focuses her practice on the provision of corporate, regulatory and compliance counseling to healthcare and life sciences companies. The cornerstone of her practice is providing guidance to clients regarding HIPAA and the HITECH Act, the Medicare and Medicaid fraud and abuse laws…

Kimberly focuses her practice on the provision of corporate, regulatory and compliance counseling to healthcare and life sciences companies. The cornerstone of her practice is providing guidance to clients regarding HIPAA and the HITECH Act, the Medicare and Medicaid fraud and abuse laws, the Stark Law, Medicare coverage and reimbursement rules, and state healthcare laws and regulations.

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Photo of Anna Timmerman Anna Timmerman

Anna’s practice focuses on healthcare transactional and regulatory matters for a variety of healthcare providers, including dental support organizations, management services organizations, ambulatory surgery centers and surgery center management companies, behavioral health companies and hospitals, as well as private equity sponsors in their…

Anna’s practice focuses on healthcare transactional and regulatory matters for a variety of healthcare providers, including dental support organizations, management services organizations, ambulatory surgery centers and surgery center management companies, behavioral health companies and hospitals, as well as private equity sponsors in their platform and subsequent transactions.

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Photo of Kristen H. Chang Kristen H. Chang

Kristen assists clients in traversing regulatory, compliance, corporate transactional, and reimbursement issues related to the healthcare industry. She counsels clients on the federal Anti-Kickback Statute, Stark Law, Medicare policy, state fraud and abuse laws, state corporate practice of medicine laws, state licensure laws…

Kristen assists clients in traversing regulatory, compliance, corporate transactional, and reimbursement issues related to the healthcare industry. She counsels clients on the federal Anti-Kickback Statute, Stark Law, Medicare policy, state fraud and abuse laws, state corporate practice of medicine laws, state licensure laws, HIPAA, fee-splitting prohibitions, and other regulatory matters.

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  • Posted in:
    Health Care and Life Sciences
  • Blog:
    The FCA Insider
  • Organization:
    McGuireWoods LLP
  • Article: View Original Source

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