Foley & Lardner LLP partner Judith Waltz is quoted in the article, “New OIG Compliance Program Guidance Puts Risk Assessment in Committee’s Hands,” in the Report on Medicare Compliance, published by the Health Care Compliance Association.
Waltz, who is co-chair of Foley’s Health Care Practice Group, offered her perspective on the new general compliance program guidance from the U.S Department of Health and Humans Services Office of Inspector General’s (OIG). She explained that as a result of the new guidance, every compliance program will at a minimum need to be tweaked in response.
“Compliance programs are, or should be, living, breathing, fluid enterprises,” Waltz explained. She noted that some of the new material in the guidance may be familiar already as it has been foreshadowed in OIG conference presentations and changes to corporate integrity agreements over the past three years.
OIG is taking “an unnecessarily narrow view of what compliance officers should be doing by limiting their roles,” Waltz added. “The theme should be to encourage compliance efforts, and it doesn’t need to be done by prescribing what the compliance officer can and can’t do. Each compliance program needs to have an approach that works for its organization, and that should be encouraged with flexibility to support the compliance culture at that entity.”