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

The Clinical and Interpersonal Skills That Define Excellence in Patient-Centered Care
Health
June 2, 2026
The Advanced Nursing Credentials That Open Doors to Leadership Roles
The Advanced Nursing Credentials That Open Doors to Leadership Roles
Nursing
June 2, 2026
The Advanced Practice Nursing Roles Worth Knowing About Before You Specialize
The Advanced Practice Nursing Roles Worth Knowing About Before You Specialize
Nursing
June 2, 2026
Language Access in Healthcare: What Hospitals Still Get Wrong in 2026
Hospital Administration Technology
May 29, 2026

You Might also Like

The Cookie-Cutter Medicine Fallacy

June 8, 2012

GOP Leaks Preliminary Details on Medicaid Reform Plans

April 2, 2011

Cadillac tax or Yugo tax: Which one would be better?

September 10, 2015
physician wellness
BusinessHospital AdministrationMedical EducationWellness

Physician Wellness: Why It’s Such a Struggle

March 26, 2013
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?