The OIG’s compliance program guidance — first issued for hospitals in 1998 and consolidated into the General Compliance Program Guidance in November 2023 — sets out seven elements that any defensible compliance program needs to cover. Exclusion screening is one piece of one element, but it’s the piece that shows up in every CIA, every self-disclosure, and every False Claims Act matter. A program that screens well on paper but fails in practice is the program the OIG finds during an audit. This hub covers what the full compliance program looks like around the screening function.
What this guide will cover
- The seven elements of an effective compliance program (1998 guidance + 2023 GCPG update)
- Written policies and procedures — the documents the OIG expects to see
- Compliance officer and committee roles
- Training and education programs — frequency, content, documentation
- Communication channels including the compliance hotline
- Monitoring, auditing, and risk assessment — the layer where screening lives
- Enforcement of standards and discipline
- Prompt response to detected offenses and corrective action
- How the OIG’s Corporate Integrity Agreements shape program expectations
- Board and audit committee oversight
Read now
- The Definitive Guide to OIG Exclusions — screening within the larger compliance program.
- The Legal Guide to OIG Exclusions — regulatory framework that drives program design.
- Compliance Hotline — our hotline product, one element of the seven.
- OIG General Compliance Program Guidance (official) — the 2023 GCPG.
- Free Compliance Assessment — 10-question diagnostic.
Talk to our team
If your compliance program is strong on policy but thin on operational execution — monthly screening, vendor coverage, hotline response — we can help close the operational gap without replacing the policy work you’ve already done.