CLIENT ALERT: OIG Encourages Compliance Programs for Grantees and Health Care Providers Serving American Indian and Alaska Native (AI/AN) Communities

By | Published On: May 25, 2022

In two recently released training modules, the Department of Health and Human Services, Office of the Inspector General (OIG) encourages programs in Indian Country, including Head Start, Low Income Home Energy Assistance programs and Indian Health Services (IHS), to develop compliance programs.

The training modules – one for grantees and one for health care providers – include an overview of fraud, waste and abuse, and a summary applicable federal fraud and abuse laws (including the False Claims Act, Civil Monetary Penalties Law, Anti-Kickback Statute, Stark Law).

Compliance Recommendations for Grantees and Health Care Providers

To prevent fraud, waste and abuse, the OIG urges all programs in Indian Country to “establish a compliance program to proactively avoid the vulnerabilities” and “build robust internal controls as part of your compliance program.” Grantees and health care providers serving AI/AN communities should develop and implement a compliance program that includes the OIG’s seven elements:

  • Designating a compliance officer
  • Implementing written policies and procedures
  • Conducting training and education
  • Developing open lines of communication
  • Conducting internal monitoring and auditing
  • Responding to detected offenses
  • Enforcing disciplinary standards through well-publicized guidelines

Implementing a compliance program is especially important given the OIG’s past audits and the OIG’s continued focus on IHS, grantees and health care providers serving AI/AN communities. The OIG’s current Work Plan includes multiple audits of programs in Indian Country, including audits related to COVID-19 (use of grant funds by IHS and grantees for testing, supply distribution by IHS, vaccine distribution policies), background verification processes at IHS- and tribally-operated health facilities, and cybersecurity controls for HIS telehealth technologies.

Tribal Compliance Training

To review the OIG’s training modules, please visit the OIG’s website.

To register for FTLF’s next two-day training on the Seven Elements of a Compliance Program, please visit

Ms. Pledgie is a member of the New York and Massachusetts Bars and is not licensed in Washington, DC. Her practice is limited to federal health care matters.