Office of Inspector General Supplemental Compliance Program Guidance for Hospitals

On June 8, 2004, the Office of Inspector General ("OIG") of the Department of Health and Human Services ("HHS") published a draft Supplemental Compliance Program Guidance for Hospitals ("Supplemental Guidance").¹ The Supplemental Guidance is mandatory reading for anyone who works with hospitals. It describes the areas where hospitals currently are at greatest legal risk, provides guidance on other topics of interest to hospitals, and contains extensive references to other materials that provide further guidance and clarification on various compliance issues. Comments on the Supplemental Guidance may be submitted to the OIG until July 23, 2004.

The Supplemental Guidance is intended to emphasize risk areas that have emerged since the 1998 publication of the OIG’s original Compliance Program Guidance for Hospitals ("Original Guidance"),² and it highlights outpatient procedure coding, admissions and discharges, supplemental payment considerations, and the efficient use