OIG and DOJ Compliance Guidance Updates for Healthcare: Compliance Program Evaluation, Agency Enforcement, Best Practices
Course Details
- smart_display Format
On-Demand
- signal_cellular_alt Difficulty Level
Intermediate
- work Practice Area
Health
- event Date
Wednesday, January 29, 2025
- schedule Time
1:00 p.m. ET./10:00 a.m. PT
- timer Program Length
90 minutes
-
This 90-minute webinar is eligible in most states for 1.5 CLE credits.
This CLE webinar will guide counsel and compliance officers of healthcare providers and other stakeholders on both the U.S. Department of Health and Human Services Office of Inspector General's (OIG) and U.S. Department of Justice's Criminal Division's (DOJ) most recent compliance guidance. The panel will discuss both the OIG's and DOJ's approaches to compliance and the factors each considers when assessing whether a compliance program is effective.
Ms. Barrett is a seasoned healthcare lawyer with significant experience in analyzing federal and state healthcare laws and regulations, particularly related to fraud and abuse, health system operations, medical necessity and billing and coding. She also has significant experience in compliance matters, having served as SVP, Chief Compliance and Ethics Officer for a large health system with an academic medical center. Ms. Barrett has served as General Counsel to a multi-facility health system and has held senior in-house positions in for-profit, non-profit, and public health systems. She has also spent many years in private practice providing advice and guidance to a wide variety of healthcare providers including hospitals, ambulatory surgery centers, physicians, home health agencies, hospice providers, DME providers, labs and nursing homes. Ms. Barrett is currently an Adjunct Professor at the Maurice A. Deane School of Law at Hofstra University, as well as at the Univeristy of North Carolina at Wilmington. She holds leadership positions in the ABA's Health Law Section, as Vice Chair of eHealth, Privacy & Security, as well as Vice Chair of Ethics and Professionalism. Ms. Barrett frequently speaks and writes on a wide array of health law and compliance topics.
Mr. Demske provides strategic compliance counseling for healthcare and life sciences companies. He helps clients achieve their business goals while reducing risks under the Anti-Kickback Statute, False Claims Act, and other fraud and abuse authorities in business arrangements and transactions. He advises on developing and operating compliance programs, requesting advisory opinions, anticipating and addressing compliance issues, submitting voluntary disclosures, and responding to government investigations and enforcement actions. Prior to joining Goodwin, Mr. Demske served as Chief Counsel to the Inspector General, Department of Health and Human Services (HHS), where he led the provision of all legal services and advice for the HHS Office of Inspector General (OIG).
The OIG published its much-anticipated General Compliance Program Guidance (GCPG) in November 2023 as a voluntary guide to be used when creating healthcare compliance programs or when assessing existing healthcare compliance programs. This represents the first major update to OIG compliance program guidance since 2008 and applies to all individuals and entities in the healthcare industry.
While the GCPG is generally applicable to all healthcare providers, the OIG began publishing industry-specific compliance program guidance (ICPG) for different types of providers, suppliers, and other participants, with its release of the Industry Segment-Specific Compliance Program Guidance for Skilled Nursing Facilities and Nursing Facilities (Nursing Facility ICPG) on Nov. 20, 2024.
Additionally, on Sept. 23, 2024, the DOJ issued an updated version of its Evaluation of Corporate Compliance Programs (ECCP), which serves as a guide for prosecutors to use when evaluating whether and to what extent healthcare providers have effective compliance programs. It is also a valuable tool to use when preparing or evaluating the effectiveness of a compliance program.
Listen as our authoritative panel of healthcare attorneys examines the GCPG and the recently released Nursing Facility ICPG for healthcare compliance. The panel will also discuss the latest update to the DOJ's ECCP. The panel will review the federal laws involved and the compliance program infrastructure. The panel will also discuss the DOJ's and OIG's approaches to enforcement and offer best practices for compliance.
- OIG GCPG overview
- Federal laws involved
- Nursing Facility ICPG
- Future ICPGs
- DOJ ECCP overview
- Compliance program infrastructure
- DOJ and OIG approaches to enforcement
- Best practices
The panel will review these and other key issues:
- What are key takeaways for practitioners from the recent GCPG, ICPG, and ECCP guidance?
- What factors should healthcare providers consider when structuring healthcare compliance programs?
- What are best practices for healthcare providers and their counsel and compliance officers to help minimize compliance risks?
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