Understanding the Sunshine Act

Washington, D.C., partner Jesse Witten and Milwaukee partner Robyn Shapiro participated in a Strafford CLE webinar titled, “OIG/CMS Voluntary Self Disclosures: Updated Options and Settlements” on Tuesday, August 6.

The panel explained the pros, cons and procedural steps for disclosing under the Office of Inspector General’s Self-Disclosure Protocol using the recent update as a springboard for the discussion and under the CMS Self-Referral Disclosure Protocol. They also discussed effective approaches for evaluating whether to self-report violations and for achieving favorable outcomes.

Specifically the panel reviewed these key questions:

• What are some key aspects of the April 2013 updated Provider Self-Disclosure Protocol?
• What factors should healthcare providers consider when determining whether and when a potential Stark Law violation should be disclosed?
• What are the best practices for healthcare providers and their counsel when preparing the SDP disclosure submission?