Sumner, Waltz Examine General Compliance Program Guidance in National Journal
Published March 29, 2024

Sumner, Waltz Examine General Compliance Program Guidance in National Journal

An article written by PYA Principal and Chief Compliance Officer Shannon Sumner and Foley & Lardner Partner and Co-chair of the Health Care Practice Group Judy Waltz was featured in a recent issue of the Journal of Health Care Compliance. The national bimonthly publication provides current and emerging trends and issues related to healthcare compliance.

Sumner and Waltz’s article, “OIG’s General Compliance Program Guidance: How to Refresh Existing Compliance Programs,” is part of a column in the journal dedicated to PYA thought leadership. The article examines key insights from the General Compliance Program Guidance (GCPG) released in November 2023 by the Office of Inspector General (OIG) and provides action items to strengthen compliance programs.

In their article, Sumner and Waltz state, “Although OIG confirms that adherence to the GCPG is not mandatory, its suggestions are likely to become the standards against which the compliance programs will be measured.”

Among the many suggestions in the updated GCPG, the authors highlight two recommendations for immediate consideration: conducting annual internal risk assessments and checking state-specific exclusion lists. Sumner and Waltz explain the GCPG’s new guidance on involving the compliance committee and using external resources with risk assessments. They also share the GCPG’s recommendation for screening employees and contractors using both the federal and state exclusion lists. They provide additional guidance on using state-specific laws and lists and give recommendations for next steps.

The Journal of Health Care Compliance is published by Wolters Kluwer. Sumner and Waltz’s article is in the March-April 2024 issue, which is available to subscribers of the journal.

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