OIG General Compliance Program Guidance · 2023
The 7 elements,
made operational
The OIG’s GCPG defines what an effective healthcare compliance program must contain. Ethoshield builds every element into your organization not as a checklist, but as a living structure. Click any card to expand.
Nursing Facility Risk Areas
Where regulatory scrutiny concentrates
The OIG and CMS consistently flag these areas in nursing facility enforcement actions. Your compliance program must address each with documented controls.
| Risk area | Regulatory source | Priority | Ethoshield coverage |
|---|---|---|---|
| Medicare/Medicaid billing accuracy | FCA, OIG ICPG | High | Audit protocols, billing review |
| Staffing levels & adequacy | CMS SNF regulations | High | Policy design, monitoring controls |
| MDS documentation accuracy | CMS RAI Manual | High | Documentation review, training |
| Resident rights & dignity | OBRA, F-tags | High | Policy architecture, training |
| Therapy documentation | Medicare Part A/B | High | Audit protocols, corrective action |
| Anti-kickback arrangements | AKS, OIG safe harbors | Medium | Contract review, advisory |
| Vendor & supplier relationships | AKS, FCA | Medium | Vendor screening, policy review |
| Employee exclusion screening | OIG LEIE, state exclusions | Medium | Exclusion monitoring protocols |
Engagement process
From assessment to ongoing program
Every engagement starts with your actual risk profile not a template. Here’s how we build from there.
1
Organizational risk assessment
We review your payer mix, survey history, staffing structure, existing policies, and operational workflows to identify your specific compliance gaps and risk concentrations.
2
Program design & infrastructure
Based on the assessment, we build or refine your compliance architecture written standards, reporting mechanisms, training plan, and audit schedule calibrated to your size and risk profile.
3
Implementation & leadership integration
We work directly with your leadership team to implement the program, establish governance structures, and ensure the compliance function has appropriate authority and reporting lines.
4
Ongoing monitoring & advisory
Compliance is not a one-time project. We serve as your ongoing compliance partner monitoring, auditing, responding to incidents, and keeping your program current as regulations and your organization evolve.
See how your program measures up
We’ll walk through the 7 elements against your current structure and show you exactly where the gaps are.
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