OIG Compliance Guidance

A recent article from Skilled Nursing News discussed the OIG’s Nursing Facility Industry Segment-Specific Compliance Program Guidance, specifically addressing the Medical Director requirements and QAPI projects.

Quick history lesson: The OIG began publishing Compliance guidance in 1998, impacting hospitals and nursing facilities. This continued for the next 10 years, expanding into areas such as pharmaceuticals.

In 2023, the OIG began a modernization initiative to update the compliance guidance, entitled General Compliance Program Guidance (GCPG).

Industry-Specific Compliance Program Guidance (ISPG) began coming out in 2024 with the release of the Nursing Facility ISPG. The ISPGs offer industry-specific compliance risks and opportunities. (Additional ISPGs for Medicare Advantage, Hospital, Clinical Laboratory, Pharmaceutical Manufacturer, and Hospice are supposed to be released at some point.)

While the concept of compliance is not new or required for nursing facilities, Nursing Facilities may want to consider this time as an opportunity to reflect and refine on current policies, procedures, and practices.

Over the next few weeks, I’ll dive into the Nursing Facility ISPG, the Essential Elements of an Effective Compliance program, and how Nursing Facilities can incorporate the two into their work in a way that honors and supports the processes already in place.

rachel@pathforgedconsulting.com