New Updates to the OIG's Hospital Compliance Guidance

On Tuesday, June 8, 2004, the Office of Inspector General (the “OIG”) issued a Draft Supplemental Compliance Program Guidance for Hospitals (the “Guidance”), updating its compliance program guidelines originally published on February 23, 1998. Both the original compliance program guidance and the new Guidance offer guidelines that hospitals should consider when developing and implementing a corporate compliance plan. The Guidance offers new compliance recommendations and an expanded discussion of risk areas. In preparing this supplement, the OIG took into account recent changes to hospital payment methodologies, evolving industry practices, and the OIG's current enforcement policy and identified areas of risk.