Episode 103 ·
Part 2: OIG General Compliance Program Guidance: A Discussion with Alex Krouse with Parkview Health
Send us Fan Mail Be careful what you put in writing. In this special episode, Captain Integrity Bob Wade discusses the recent General Compliance Program Guidance (GCPG) issued by the OIG (Office of Inspector General) with Alex Krouse, Associate General Counsel - Provider Arrangements at Parkview Health. This is Part 2 of a 2-part episode, originally recorded as a webinar for the American Association of Provider Compensation Professionals (AAPCP) on November 16, 2023. Hear the questions and issues the OIG has offered, when Fair Market Value (FMV) becomes irrelevant, why emails are evil, the manner in which remuneration is determined, and why you need to be careful with deals with family members of physicians. Email Bob to get the slides and learn more at CaptainIntegrity.com
- Fair Market Value
- Investigations and Enforcement
- Compliance Programs
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Companion article
OIG General Compliance Program Guidance – A Discussion with Alex Krouse of Parkview Health
Episode Date: December 2023
In this episode of Stark Integrity, Bob Wade (“Captain Integrity”) of Nelson Mullins is joined by Alex Krouse, Associate General Counsel at Parkview Health, to break down Part 1 of the OIG’s updated General Compliance Program Guidance (GCPG).
Together, Wade and Krouse provide a practical, real-world perspective on what the updated guidance actually means for healthcare organizations.
From Theory to Practice
While Bob Wade frames the regulatory backdrop, Alex Krouse brings an in-house, operational lens, emphasizing how compliance programs function day-to-day inside a health system.
A key takeaway from Krouse’s perspective:
Compliance cannot live on paper—it has to work in practice.
The updated OIG guidance reinforces that expectation by focusing on:
- Real-world implementation
- Integration into operations
- Continuous evaluation of effectiveness
Moving Beyond Checklists
Wade and Krouse both highlight the OIG’s shift away from rigid, checklist-style compliance programs toward:
- Risk-based frameworks
- Tailored program design
- Ongoing monitoring and adaptation
As Krouse emphasizes, organizations need to ask:
“Does our program actually address our biggest risks?”
—not just whether required elements exist.
The Core Elements—Still Critical
The discussion also reinforces that the traditional compliance elements remain foundational:
- Policies and procedures
- Training and education
- Reporting mechanisms
- Auditing and monitoring
But as Wade and Krouse explain:
Effectiveness—not existence—is now the focus.
Leadership and Accountability
From his role at Parkview Health, Alex Krouse underscores the importance of leadership engagement:
- Compliance must be supported at the top
- Accountability must be clearly defined
- Programs must be integrated across departments
This aligns with the OIG’s expectation that compliance is an enterprise-wide responsibility, not just a compliance department function.
Final Thoughts
This conversation between Alex Krouse of Parkview Health and Bob Wade of Nelson Mullins sets the tone for the broader series on the OIG guidance:
Modern compliance requires more than structure—it requires execution.
As both emphasize, the real question is no longer:
“Do you have a compliance program?”
But:
“Does your compliance program actually work?”
Click here to listen to this Stark Integrity Podcast Episode:
https://podcasts.apple.com/us/podcast/part-1-oig-general-compliance-program-guidance-a/id1588939373?i=1000638423175&l=fr-FR