Seven Elements Self-Scoring
Score your compliance program against the OIG's seven elements of an effective compliance program, as updated by the 2023 General Compliance Program Guidance. OIG states that the GCPG "is voluntary guidance" and "is not binding on any individual or entity", so what you are scoring is alignment with the guidance OIG uses to evaluate programs, not legal compliance. Work through each element on a four-level maturity scale, then open the Scorecard tab for an overall score, a color-banded breakdown by element, and an auto-generated gap summary you can copy or print. The GCPG is still the general guidance and applies across the industry, but OIG now layers industry segment-specific guidance on top of it: a Nursing Facility ICPG dated November 20, 2024 and a Medicare Advantage ICPG dated February 3, 2026, with hospital, clinical laboratory, pharmaceutical manufacturer and hospice segments listed as coming. If you are in a segment that has one, score here and then work your ICPG as well, because this tool scores the general elements only.
The seven elements are not a checklist to complete once; they describe a system that has to keep running. Each statement below asks whether a specific practice is actually operating, not just written down. Answer honestly against the last 90 days, not against the policy manual.
Not started
No meaningful practice exists yet; this is aspirational, not real.
Informal only
Happens sometimes, driven by individual initiative rather than a defined process.
Documented but inconsistent
A real process exists and is written down, but execution is uneven or unproven.
Operating & evidenced
Running consistently, and you could produce evidence of it on short notice.
Items flagged NEW 2023 reflect expectations the OIG sharpened or added in the November 2023 General Compliance Program Guidance, annual risk assessments, quality of care as a named risk area, compliance-officer independence, a disclosure log, monthly exclusion screening, licensure verification, and its view of prompt reporting. They are expectations rather than requirements: OIG states that the GCPG "is voluntary guidance" and "is not binding on any individual or entity". What binds is elsewhere. The overpayment repayment deadline in 42 CFR 401.305 binds, and if you are under a corporate integrity agreement its reportable-event deadlines bind you by contract. A low score here is a gap against guidance OIG uses to evaluate programs, which is worth closing, but it is not by itself a finding of illegality.
Your overall score is the average of the seven element scores (not a flat average of every question), so no single element can outweigh the others just because it has more statements. Click any element row to jump back and fill in gaps.
This tool translates the HHS OIG's General Compliance Program Guidance (November 2023) into a self-scoring maturity assessment for general compliance-learning purposes. It is not legal advice, and it is not an audit, an attestation, or a substitute for OIG guidance itself. Brandon Goulter is not an attorney, and using this tool creates no professional advisory relationship. Scores are self-reported and stored only in your browser's local storage, nothing is transmitted or saved to any server. Verify your program's actual compliance posture with a licensed attorney or qualified compliance professional before relying on these results.