Michael Dowell Explores New OIG Compliance Expectations for MAOs

An article authored by Hinshaw partner Michael Dowell and titled “The OIG Just Raised the Bar: New Medicare Advantage Compliance Guidance You Cannot Afford to Ignore” was recently published in the May/June 2026 edition of the Journal of Health Care Compliance by Wolters Kluwer.

Adapted from a Healthcare Alert Michael published earlier this year, the article breaks down what Medicare Advantage Organizations (MAOs), delegated providers, and first-tier, downstream, and related entities (FDRs) should understand about the Office Inspector General’s (OIG) updated Medicare Advantage Compliance Program Guidance.

Although the guidance is voluntary and non-binding, Michael explains that it serves as a practical roadmap for enforcement and effective compliance programs and reflects heightened scrutiny by the Office of Inspector General (OIG), the Department of Justice (DOJ), and the Centers for Medicare & Medicaid Services (CMS).

Key Compliance Steps and Takeaways Include:

• • Reassessing compliance programs against updated risk areas;
  • Reviewing prior authorization and utilization management practices for individualized medical-necessity determinations;
  • Strengthening risk-adjustment and quality-data controls; and
  • Revisiting third-party and FDR agreements for audit rights, reporting obligations, and compliance attestations.

Michael also highlights the growing importance of oversight around AI-supported decision tools, marketing and enrollment practices, network adequacy, provider directories, and board-level visibility into Medicare Advantage compliance risks.

• • “The OIG Just Raised the Bar: New Medicare Advantage Compliance Guidance You Cannot Afford to Ignore,” Journal of Health Care Compliance, June 2026