On April 17, 2013, the Office of Inspector General of the Department of Health and Human Services (“OIG”) released an Updated Provider Self-Disclosure Protocol (“SDP”). The Updated SDP replaces OIG’s original Provider Self-Disclosure Protocol, published in the Federal Register in October 1998, and supersedes OIG’s related open letters from 2006, 2008 and 2009.
The Updated SDP reflects a number of important changes, described below.
Availability of the SDP -
OIG clarified that the SDP is available to drug and device manufacturers, not just health care providers. Consistent with this clarification, throughout the SDP, OIG refers to “disclosing parties” rather than to “providers,” as had been the case in the 1998 Protocol and subsequent open letters.
Please see full alert below for more information.
Firefox recommends the PDF Plugin for Mac OS X for viewing PDF documents in your browser.
We can also show you Legal Updates using the Google Viewer; however, you will need to be logged into Google Docs to view them.
Please choose one of the above to proceed!
LOADING PDF: If there are any problems, click here to download the file.
Topics: CMS, Corporate Integrity Agreement, Damages, Drug Manufacturers, HHS, OIG, Overpayment, Self-Disclosure Requirements
Published In: General Business Updates, Health Updates, Insurance Updates, Science, Computers & Technology Updates
DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.
© Ropes & Gray LLP | Attorney Advertising