Self-Disclosure Requirements

News & Analysis as of

OFCCP Updates Website With Resources For Section 503 Compliance

OFCCP recently updated its website with additional information for contractors to assist with their compliance with the final rule issued under Section 503 of the Rehabilitation Act. The information addresses recruiting...more

Health Care Self-Disclosure Protocols – Is It Worth It To Self-Report?

In recent years the federal government has aggressively investigated and prosecuted pharmaceutical companies and health care providers for possible violations of anti-fraud, anti-kickback and other laws. These efforts have...more

Federal Contractors Get In Compliance: New Self-Identification Form For Individuals With Disabilities Issued

New disability regulations issued by the Office of Federal Contract Compliance Programs (OFCCP) require covered federal contractors and subcontractors to invite applicants and employees to self-identify their disability...more

FCPA Compliance and Ethics Report-Episode 31-the FCPA Year in Review, Corporate Enforcement Actions [Video]

In this episode, I review the corporate FCPA enforcement actions of 2013. ...more

BBB Warns Advertisers and Web Publishers to Take Responsibility for Behavioral Advertising Disclosures

The Better Business Bureau (“BBB”) and the Direct Marketing Association (“DMA”) are in charge of enforcing the ad industry’s Self Regulatory Principles for Online Behavioral Advertising (“OBA Principles”), which regulate the...more

CMS Issues FAQs Regarding Self-Referral Disclosure Protocol

CMS has released its responses to eight frequently asked questions [PDF] regarding its Self-Referral Disclosure Protocol (SRDP). The questions fall into three categories, listed below, and respond to issues that are often...more

Swiss Banks to Receive No Credit for Customers Who Entered OVDP without Banks' Encouragement

Tax Analysts Tax Notes reports that Kathryn Keneally, assistant attorney general for the Justice Department Tax Division, said that Swiss banks that enter the IRS’s newly-offered program will receive no credit for customers...more

Former Head of Investor Relations Penalized by SEC for Selectively Disclosing Material Nonpublic Information, While...

The selective and early disclosure of material non-public information resulted in a Securities and Exchange Commission cease and desist order and civil penalties against the former head of investor relations at First Solar,...more

Right from the Source: IRS Guidance for U.S. Plan Sponsors on Fixing Mistakes and Surviving IRS Employee Plan Audits

Those of you who participated in our July 16 webinar on plan fix-it programs heard us emphasize the importance of self-audits and internal controls to increase your chances of coming out clean in an employee plan audit....more

Updated OIG Exclusion Guidance Spells Out Recommended Employee Screening Procedures

On May 8, 2013, the Office of Inspector General (OIG) published an updated bulletin that spells out the frequency with which employers should check the OIG’s List of Excluded Individuals and Entities and clarifies which...more

Healthcare Providers And Self-Disclosure Of Violations

The healthcare industry has a long history of innovative compliance policies and strategies. ...more

Shorts on Long Term Care - June 2013

In this issue: - What’s Up With Nursing Facility “Mandatory” Corporate Compliance Programs? - Updated OIG Exclusion Guidance Spells Out Recommended Employee Screening Procedures - General Assembly Calls...more

2013 Healthcare Fraud and Abuse Bootcamp Webinar Series, Part V: Compliance

Bill Mathias of Ober|Kaler's Health Law Group presented on compliance as a part of the 2013 Healthcare Fraud and Abuse Bootcamp Webinar Series sponsored by the American Health Lawyers Association. This webinar...more

Practical Tips for Providers Managing Risks Related to Excluded Parties and the Implications of the OIG's Recent Special Advisory...

On Wednesday, May 8, 2013, the Health and Human Services Office of Inspector General (OIG) released a Special Advisory Bulletin on the Effect of Exclusion from Participation in Federal Health Care Programs (FHCPs). This...more

OIG's Special Advisory Bulletin on the Effect of Exclusion—Continuing the Focus on Individual Accountability

On May 8, 2013, the U.S. Department of Health and Human Services' Office of Inspector General ("OIG") released an Updated Special Advisory Bulletin on the Effect of Exclusion from the Participation in Federal Health Care...more

OIG Releases Updated Provider Self-Disclosure Protocol

On April 17, 2013, the Office of the Inspector General (OIG) of the United States Department of Health and Human Services released an updated Provider Self-Disclosure Protocol (SDP). As self-described, OIG updated the SDP to...more

Health Law Alert: OIG Issues Updated Special Advisory Bulletin On The Effect Of Exclusion From Participation In Federal Health...

On May 8, 2013, the U.S. Department of Health and Human Services Office of the Inspector General (OIG) issued an updated Special Advisory Bulletin on the effect of exclusion from participating in federal health care programs....more

Updated OIG Bulletin on Effect of Exclusion from Federal Health Care Programs

On May 8, 2013, the U.S. Department of Health & Human Services, Office of Inspector General (“OIG”), issued an updated “Special Advisory Bulletin on the Effect of Exclusion from Participation in Federal Health Care Programs”...more

OIG Issues Revised Provider Self-Disclosure Protocol

On April 17, 2013, the Office of Inspector General (OIG) of the United States Department of Health and Human Services (HHS) revised its Provider Self-Disclosure Protocol (SDP), originally published in 1998, and updated in...more

Lessons Learned from the Parker Drilling DPA and Ralph Lauren NPA [Video]

In the two most recent corporate Foreign Corrupt Practices Act (FCPA) enforcement actions, the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) to communicate not only what they believe constitutes a...more

Actions Taken During A FCPA Enforcement Action - Lessons From Parker Drilling And Ralph Lauren

In the two most recent corporate Foreign Corrupt Practices Act (FCPA) enforcement actions, the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) to communicate not only what they believe constitutes a...more

OIG Releases Updated Self-Disclosure Protocol

On April 17, 2013, the U.S. Department of Health and Human Services Office of Inspector General (OIG) released an updated Provider Self-Disclosure Protocol (Protocol) that supersedes and replaces the protocol published in the...more

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...more

OIG Unveils Updated Self-Disclosure Protocol

In 1998, the Department of Health and Human Services' Office of Inspector General ("OIG") published the Self-Disclosure Protocol ("SDP"), which provides a mechanism through which health care providers may voluntarily report...more

Updated Self-Disclosure Protocol Clarifies Disclosure Process and Obligations

Individuals and entities subject to the Civil Monetary Penalty Law (CMP) have received clarification regarding the process for disclosing and resolving potentially unlawful conduct involving the federal health care programs...more

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