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Healthcare · Compliance

The OIG Seven Fundamental Elements

The contract-operations view. The OIG General Compliance Program Guidance Seven Elements are the benchmark for program design, and several of them run through the contract record.

Regulatory requirements for contract management

These are the requirements that bear on contracts and the contract record. It is general information, not legal advice.

  • The OIG General Compliance Program Guidance (November 2023) is voluntary, nonbinding, and the de facto benchmark for healthcare compliance program design.
  • The Seven Elements are: written policies and standards of conduct; a compliance officer and committee; training and education; lines of communication; enforcing standards; risk assessment, auditing, and monitoring; and prompt response and corrective action.
  • Industry-Specific Compliance Program Guidance overlays add segment risk frames (Nursing Facility, November 2024; Medicare Advantage, February 2026; Hospital forthcoming).
  • An annual cadence often becomes the baseline: annual risk assessment, policy refresh, training, and a board resolution affirming program effectiveness.

How a compliant program operates

The contract-side cadence a well-run program runs on.

  • The policy and clause library (Element 1) is versioned, with annual review and CEO and Board endorsement records.
  • Training-requirement language (Element 3) lives in employment and contractor agreements.
  • The contract intelligence dashboards (Element 6) are the risk-assessment, auditing, and monitoring data layer.
  • Contract amendments (Element 7) document corrective action where it concerns a contract term.

Do the Seven Elements run through your contract record?

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How Contract Logix supports the work

Contract Logix holds the policy and clause library with versioning, an annual review workflow, and CEO and Board endorsement records, provides configurable contract intelligence dashboards as the audit-data layer for the annual enterprise compliance risk assessment, and captures contract amendments as the corrective-action artifact with a time-stamped audit trail. Explore the repository, workflow, the Contract Intelligence Engine, and the Contract Intelligence Dashboard.

Get the full OIG Seven Fundamental Elements whitepaper

The whitepaper covers the operational requirements, the regulatory citations and deadlines, and where compliance programs most often fall short, with the contract-operations view throughout.

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Frequently asked questions

Is Contract Logix a compliance program?

No. It supports the contract-side of the Seven Elements: the policy library, the audit-data layer, and corrective-action amendments.

Does it replace a governance, risk, and compliance platform?

No. The risk analysis and case management live in the governance, risk, and compliance platform. The contract record is the source of contract data and the corrective-action amendments.

Can policies carry Board endorsement records?

Yes. The policy and clause library is versioned with CEO and Board endorsement and an annual review workflow.

Disclaimer. This page is general information about the OIG General Compliance Program Guidance and contract operations. It is not legal advice and does not create an attorney-client relationship. Consult qualified counsel for advice on your obligations.

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