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April 23, 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.

©2014 von Briesen & Roper, s.c

About the Author

William O. Jackson, health care, employment, attorney, von Briesen, law firm
Attorney

Bill Jackson is a member of the Health Care Practice Group where he focuses on both health law and employment law.

Prior to joining von Briesen & Roper, Bill worked as an Administrative Fellow at a hospital system in western Wisconsin. In this capacity, he worked on legal and administrative matters, including strategic planning, hospital program development, physician contracting, and compliance. Bill has also worked in the corporate office of a large, multistate hospital system and in administration at a community hospital.

During law school, Bill was a member of the...

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