Got an opinion on how to improve or change the HHS Office of Inspector General’s self-disclosure protocol? OIG wants to know because it’s considering revisions, according to an announcement in a recent Federal Register. The self-disclosure protocol, which allows providers to admit potential fraud against federal health care programs in exchange for lesser penalties, was implemented in 1998. Since then, OIG says it has resolved 800 self-disclosures and recovered $280 million through the self-disclosure protocol. Now, however, “we are soliciting comments, recommendations and other suggestions from concerned parties and organizations on how best to revise the protocol to address relevant issues and provide useful guidance to the healthcare industry,” OIG says.
What do providers think of the self-disclosure protocol?
Do they get a fair shake from OIG when they use it?
Any suggestions for changes to the OIG protocol? What about any changes to CMS’s self-referral disclosure protocol, which is for Stark-only violations?