By Adam Turteltaub

In addition to releasing its General Compliance Program Guidance, the OIG at HHS announced plans to publish a series of Industry Segment-Specific Compliance Program Guidances (ICPG). The first of these, addressing nursing facilities, was released in November 2024.

As CJ Wolf, Professor in healthcare Administration at BYU Idaho explains in this podcast, the first ICPG is instructive both for skilled nursing facilities (SNFs) and those looking to anticipate what will be coming in future ICPGs. Currently, three more are expected to be published in 2025: Medicare Advantage, hospital and clinical laboratories. Two additional ICPGs – pharmaceutical manufacturers and hospice – are also planned, but with a publication date as yet to be determined.

There are several notable elements to the SNF ICPG. First, it interlinks compliance, quality of care and quality of life for patients. Second, there is an entire supplement focused on reimbursement, raising the scrutiny level of billing compliance. It addresses the prospective payment system, value-based payment models, Medicare Part D, Medicare Advantage, and Medicaid managed care, amongst other issues.

When it comes to Anti-Kickback, the ICPG provides specific examples that are close to home for skilled nursing facilities. These hot points include free or below fair market value goods and services, discounts, arrangements for services and supplies, pharmacist relationships, care coordination, value-based care arrangements and join ventures.

It is expected that future ICPGs will also have a focus on the Anti-Kickback statute. CJ also anticipates future guidances to continue to focus on greater accuracy and quality of care.

Listen in, whether you are working at a SNF or looking to learn what likely comes next with ICPGs.

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