September 14, 2014
September 13, 2014
September 12, 2014
Health and Human Services Office of Inspector General (OIG) Releases Updated Self-Disclosure Protocol
On Wednesday, the U.S. Department of Health and Human Services Office of Inspector General (OIG) released its updated Provider Self-Disclosure Protocol (SDP), under which providers may report and settle potential liability under the civil monetary penalty law. The updated SDP replaces the OIG’s previous protocol published in 1998 and three subsequent OIG Open Letters from 2006, 2008, and 2009.
The OIG noted that parties using the SDP generally pay lower penalties than in government-initiated investigations. This lower penalty is usually 1.5 times single damages. The SDP also outlines the process for disclosing generally as well as for specific conduct related to false billing, excluded persons, and involving the anti-kickback statute and Stark law. Finally, the SDP sets minimum settlement amounts of $50,000 for kickback-related disclosures and $10,000 for all other disclosures.
The Provider Self-Disclosure Protocol can be found here.
<span class="advertise"> Advertisement </span>
- Employer Shared Responsibility Payments and Reporting Requirements Under the Affordable Care Act: Code Sections 6055 and 6056
- Eighth Circuit Clarifies False Claims Act Pleading Standards for Whistleblowers
- When a Worker Loses an Arm, Who Knows About It?
- Judge Requires PhRMA To Initiate New 340B Orphan Drug Lawsuit to Challenge Interpretive Rule
- Looking Towards the Future of Pharmaceuticals in Africa
- National Institute of Standards and Technology (NIST) Issues Draft Report Enumerating Risks and Protections to Consider When Evaluating Mobile Apps for Your Enterprise