By using this site, you agree to the Privacy Policy and Terms of Use.
Accept
Health Works CollectiveHealth Works CollectiveHealth Works Collective
  • Health
    • Mental Health
  • Policy and Law
    • Global Healthcare
    • Medical Ethics
  • Medical Innovations
  • News
  • Wellness
  • Tech
Search
© 2023 HealthWorks Collective. All Rights Reserved.
Reading: New OIG Self-Disclosure Protocol
Share
Notification Show More
Font ResizerAa
Health Works CollectiveHealth Works Collective
Font ResizerAa
Search
Follow US
  • About
  • Contact
  • Privacy
© 2023 HealthWorks Collective. All Rights Reserved.
Health Works Collective > Policy & Law > New OIG Self-Disclosure Protocol
Policy & Law

New OIG Self-Disclosure Protocol

David Harlow
David Harlow
Share
2 Min Read
SHARE

The OIG released an updated self-disclosure protocol this week, about ten months after putting out a call for comments on the old protocol. The new protocol imposes some new burdens on the disclosing entity, such as a shorter timeline for internal investigations and reporting, and higher minimum fines.

The OIG released an updated self-disclosure protocol this week, about ten months after putting out a call for comments on the old protocol. The new protocol imposes some new burdens on the disclosing entity, such as a shorter timeline for internal investigations and reporting, and higher minimum fines.

Accoridng to the OIG, the benefits of working through the OIG self-disclosure program include lower fines (i.e., lower multipliers of damages than would otherwise be assessed) and an almost certain exemption from entering into a corporate integrity agreement. The OIG will work with DOJ so that if a False Claims Act issue is uncovered it may be dealt with through this mechanism; ordinarily, the SDP is applicable only to matters where Fraud and Abuse CMPs may be assessed by the OIG. Since health care fraud may implicate numerous federal regulatory structures administered by different agencies, it is important to remember that Stark-only (i.e., physician self-referral) violations (unlike those that are triggered by the same facts that trigger a Fraud and Abuse (i.e., anti-kickback) violation) should be disclosed through the physician self-referral disclosure protocol.

It is of course preferable to prevent fraud and abuse rather than disclose and remediate it. Health care providers should invest in compliance programs that include educational and audit components. But if all that doesn’t work, there is at least some comfortin the availability of the self-disclsoure protoocol.

David Harlow
The Harlow Group LLC
Health Care Law and Consulting

TAGGED:OIG
Share This Article
Facebook Copy Link Print
Share

Stay Connected

1.5kFollowersLike
4.5kFollowersFollow
2.8kFollowersPin
136kSubscribersSubscribe

Latest News

new talent in nursing
The Fast-Track Paths Bringing New Talent Into the Nursing Workforce
Career Nursing
November 30, 2025
AI agents in healthcare
AI Agents in Healthcare: How Sully.ai’s Virtual Team is Transforming Hospital Operations
Hospital Administration Technology
November 26, 2025
hospitality jobs health benefits
The Health Benefits of J-1 Hospitality Careers
Career
November 23, 2025
healing care
Why Healing Spaces Depend On Healthy Building Systems
Infographics News
November 19, 2025

You Might also Like

antibiotics overuse
Global HealthcarePolicy & LawPublic Health

Attack of the Superbugs: Time to Stand Up Against the Antibiotics Feeding Frenzy

December 1, 2013
medicare
Health ReformPolicy & LawPublic Health

What Is the Scoop with Medicare?

May 15, 2013

OTC Drugs Should Qualify as Medical Expense for Tax Purposes

August 5, 2011

Can the Gang of Six Change the Way We Pay For Health Care?

July 20, 2011
Subscribe
Subscribe to our newsletter to get our newest articles instantly!
Follow US
© 2008-2025 HealthWorks Collective. All Rights Reserved.
  • About
  • Contact
  • Privacy
Welcome Back!

Sign in to your account

Username or Email Address
Password

Lost your password?