The U.S. Department of Health & Human Services Office of Inspector General (“OIG”) has long been the north star for health care entities seeking guidance on creating and implementing an effective compliance program. As the author of the General Compliance Program Guidance (“GCPG”), OIG has used its years of investigative and oversight experience with health care entities to identify and recommend best practices for a wide range of entities in the U.S. health care industry.

To further OIG’s assistance to specific health care industry segments, it announced its intent to release a series of Industry Segment-Specific Compliance Program Guides. These guides provide non-binding assistance on issues and risks related to that particular industry segment.

In February 2026, OIG released its second Industry Segment-Specific Compliance Program Guidance (“ICPG”). This ICPG’s focus is on Medicare Advantage (“MA”) and provides OIG’s first MA-focused update since 1999. The ICPG reflects how government enforcement and scrutiny of the Medicare Advantage program have evolved over the past 25 plus years and highlights key risk areas and their potential mitigation.

The ICPG addresses several areas that should be familiar to those who follow the Medicare Advantage program. Highlights include a discussion of the risks and recommended best practices for these key areas: 1) Access to Care; 2) Marketing and Enrollment; 3) Risk Adjustment; 4) Quality of Care; 5) Oversight of Third Parties; 6) Relationships with Vertically Integrated Organizations and other Ownership Structures; and 7) Submission of Accurate Claims.

OIG designed the IGPG to be a user-friendly tool as a companion to the GCPG. In both documents, the OIG describes potential risks and offers strategies to mitigate these risks. Where tied to a regulatory requirement, the OIG provides a citation to the regulation. The OIG intends the ICPG to be used by MA entities to complete their own risk assessment and implement one or more of the proffered mitigation strategies.

Practical Takeaways

All entities and individuals participating in or engaged with the MA program should review the ICPG and evaluate alignment with the new guidance. Medicare Advantage Organizations and other affiliated parties should consider conducting compliance program assessments and reviewing specific workflows related to key risk areas such as risk adjustment, third-party oversight, compensation to marketing brokers and agents and the evolving use of artificial intelligence.

For more information on the ICPG or how Hall Render can assist you in implementing this guidance, please contact:

Special thanks to Summer Associate Wyatt Poer for his assistance with the preparation of this article.

Hall Render blog posts and articles are intended for informational purposes only. For ethical reasons, Hall Render attorneys cannot give legal advice outside of an attorney-client relationship.

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