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OIG Nursing Facility Compliance Program Recent Guidance: Other Risk Areas

July 2025
Intelligence That Works

Nursing facilities: How closely are you monitoring high-risk areas outlined by OIG?

On November 20, 2024, the Department of Health and Human Services Office of Inspector General (OIG) published an updated Industry Segment-Specific Compliance Program Guidance (ICPG) document for nursing facilities. OIG tailored the ICPG to risk areas specific to the nursing facility industry segment and recommended compliance measures that facility operators can take to reduce risks. OIG broke down the four broad sections of risks into Quality of Care and Quality of LifeMedicare and Medicaid Billing RequirementsFederal Anti-Kickback Statute; and Other Risk Areas.

This article addresses the final category, Other Risk Areas, which contains OIG’s recommendations for discrete risks including:

  1. Related-party transactions;
  2. Physician Self-Referral Law;
  3. Anti-supplementation;
  4. HIPAA Privacy, Security, and Breach Notification Rules; and
  5. Civil rights.

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