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OIG and DOJ Compliance Plan and Important Updates for 2024

Event Materials (Key Required)

On November 6, 2023, the OIG released its New General Compliance Program Guidance (GCPG). The GCPG is intended to serve as a voluntary reference guide for the health care compliance community and other healthcare stakeholders discussing general compliance risks and compliance programs. The GCPG addresses applicable federal healthcare laws, the “seven elements” of a compliance program, adaptions for small and large entities, and other compliance considerations. This is off the heels of the DOJ’s updated guidance issued in March 2023 regarding the DOJ’s Evaluation of Corporate Compliance Programs. Further, the OIG announced its intent to publish industry-specific Compliance Program Guidance.

All healthcare providers are required to have a corporate compliance program that is adequate and effective based on the size and scope of the organization. Providers should evaluate their existing corporate compliance programs as it is clear that these are coming under increased scrutiny by the OIG and DOJ – especially where there is a compliance issue under investigation by an auditing agency.

Learning Objectives:
  • Understand the elements of a corporate compliance program
  • Explore the recent OIG guidance
  • Review important updates on corporate compliance
  • Discuss DOJ review and expectations of healthcare providers
  • Review recent enforcement actions
  • Discuss future guidance
Areas Covered in the Session:
  • Is Your Corporate Compliance Plan Up-to-Date?
  • Corporate Compliance Overview
  • OIG Guidance
  • OIG Guidance – Seven Elements of an Effective Compliance Program
    • Written Policies and Procedures
    • Compliance Leadership and Oversight
    • Training and Education
    • Effective Lines of Communication with the Compliance Officer and Disclosure Program
    • Enforcing Standards: Consequences and Incentives
    • Risk Assessment, Auditing, and Monitoring
    • Responding to Detected Offenses and Developing Corrective Action Initiatives
  • OIG Guidance- Adaptions for Small and Large Entities
  • OIG Guidance- Other Compliance Considerations
  • DOJ Evaluation of Corporate Compliance Programs
  • DOJ Corporate Compliance Program Introduction
  • Is the Corporation’s Compliance Program Well Designed?
  • Well-Designed Compliance Program
    • Risk Assessment
    • Policies and Procedures
    • Training and Communication
    • Confidential Reporting Structure and Investigation Process
    • Third Party Management
    • Mergers & Acquisitions
  • Is the Corporation’s Compliance Program Adequately Resourced and Empowered to Function Effectively?
  • Does the Corporation’s Compliance Program Work in Practice?
  • Hallmarks of Effective Compliance Programs
  • Recent Enforcement
  • What’s Next – Industry-Specific CPGs (ICPGs) for Different Subsectors
  • Helpful Tips & Tricks
    • Create Monitoring Schedule
    • Localize Compliance Training
    • Don’t Underestimate Institutional Justice
Suggested Attendees:
  • Healthcare CEOs, COOs and CFOs
  • Practice administrators
  • Compliance Officers
  • Healthcare CPAs
  • Revenue Cycle managers
  • Billers
  • Licensed Providers
  • Physicians and APPs
  • Office Managers
  • Billing Staff
  • Medical Auditors
  • Practice Managers
  • Auditors
  • Billing Companies
  • Clinic Owners
  • Chief Quality Officers
  • Senior Internal Auditors
  • Directors of Compliance
  • Regulatory/ Risk Officers
  • Government Employees
  • General Counsel
  • Compliance Attorneys
Presenter Biography:

Amanda Waesch has experience of 18 years and operates a national healthcare practice and is licensed in both Ohio and Florida. She primarily focuses her practice on healthcare, employment law, corporate law, and healthcare litigation and advises all types of employers, in particular healthcare providers, including, hospitals and physicians, on various matters.

She also chairs the firm’s litigation team that is primarily responsible for handling all reimbursement audits and appeals for her firm’s healthcare clients and heads up BMD’s Provider Relations, Audit, Appeals, and Negotiations Unit (PRAAN) which handles all-payer audits, appeals, overpayments and payment extrapolations.


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Email: care@skillacquire.com


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