Framework — OIG 7 Elements | Ethoshield
OIG General Compliance Program Guidance · 2023

The compliance
framework, explored

The OIG's GCPG defines what an effective compliance program must contain. Explore each element, assess your current state, and see where Ethoshield can help.

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8
OIG elements
2023
GCPG edition
NF
ICPG aligned
8 OIG ELEMENTS
Your Compliance Profile
Based on your self-assessment across OIG elements
0
readiness score
Complete your assessment to generate a gap summary.
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Select an element
Choose any of the 8 OIG compliance elements to explore requirements, nursing facility specifics, and how to assess your current state.
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Element 01
What the OIG requires
Nursing Facility Context
What this looks like in practice
Strong program
    Common gaps
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      Element 1 of 8

      Nursing Facility ICPG — Sector-Specific Guidance

      Beyond the 7 core elements, the OIG's Nursing Facility ICPG adds requirements for long-term care: staffing adequacy, quality of care and resident safety, resident rights and dignity, and Medicare/Medicaid billing integrity. Ethoshield's advisory model is calibrated to all of these, not adapted from generic healthcare templates.

      Nursing Facility Risk Areas

      Where regulatory scrutiny concentrates

      The OIG and CMS consistently flag these areas in nursing facility enforcement actions.

      Risk areaRegulatory sourcePriorityEthoshield coverage
      Medicare/Medicaid billing accuracyFCA, OIG ICPGHighAudit protocols, billing review
      Staffing levels & adequacyCMS SNF regulationsHighPolicy design, monitoring controls
      MDS documentation accuracyCMS RAI ManualHighDocumentation review, training
      Resident rights & dignityOBRA, F-tagsHighPolicy architecture, training
      Therapy documentationMedicare Part A/BHighAudit protocols, corrective action
      Anti-kickback arrangementsAKS, OIG safe harborsMediumContract review, advisory
      Vendor & supplier relationshipsAKS, FCAMediumVendor screening, policy review
      Employee exclusion screeningOIG LEIE, state exclusionsMediumExclusion monitoring protocols
      Engagement process

      From assessment to ongoing program

      Every engagement starts with your actual risk profile, not a template.

      1
      Organizational risk assessment
      We review your payer mix, survey history, staffing structure, existing policies, and operational workflows to identify your specific compliance gaps and risk concentrations.
      2
      Program design & infrastructure
      Based on the assessment, we build or refine your compliance architecture, written standards, reporting mechanisms, training plan, and audit schedule calibrated to your size and risk profile.
      3
      Implementation & leadership integration
      We work directly with your leadership team to implement the program, establish governance structures, and ensure the compliance function has appropriate authority and reporting lines.
      4
      Ongoing monitoring & advisory
      Compliance is not a one-time project. We serve as your ongoing compliance partner, monitoring, auditing, responding to incidents, and keeping your program current as regulations evolve.

      See how your program measures up

      We'll walk through the 7 elements against your current structure and show you exactly where the gaps are.

      Request a framework review →
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