DOJ vs. OIG: Analysis of Recently Issued Federal Compliance Documents
Within just weeks of each other, the U.S. Department of Justice (DOJ) and the U.S. Department of Health and Human Services’ Office of Inspector General (OIG) issued separate documents that health care organizations may use to design, implement, evaluate and improve their compliance programs. This eAlert provides a brief overview of each agency’s document in Sections I and II, and thereafter analyzes the documents in Section III by pointing out the important ambiguities that exist in the DOJ’s document and differences between the two agency’s positions that compliance personnel, management, and others should be aware of when utilizing these two separate documents as tools.
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