The Top 10 Things You Need To Know About The OIG’S Revised Self-Disclosure Protocol

On Wednesday, April 17, 2013, the Department of Health and Human Services’ Office of Inspector General (OIG) released an updated Self-Disclosure Protocol (SDP) governing the process by which health care providers can voluntarily identify, disclose, and resolve situations involving potential fraud involving a Federal health care program (FHCP), such as Medicare and Medicaid. This release builds on the initial SDP created in 1998, as well as additional guidance from OIG published in a series of open letters in 2006, 2008 and 2009. The OIG decided to revise the SDP in its entirety, and the revised SDP supersedes and replaces the prior SDP and open letters.

As a practical matter, the newly released SDP does not fundamentally change the system for provider self-disclosures. The OIG reaffirms that all health care providers, suppliers, or other individuals or entities who are subject to OIG’s CMP authorities, found at 42 C.F.R. Part 1003, are eligible to use the SDP. The OIG also reaffirms that the SDP is available to facilitate the resolution of matters that, in the disclosing party’s reasonable assessment, “potentially violate Federal criminal, civil, or administrative laws for which CMPs are authorized.”

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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.

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