OIG Updates Self-Disclosure Protocol

In an effort to streamline the process, the Office of Inspector General (OIG) has modified its Provider Self-Disclosure Protocol (SDP).  While OIG continues to strongly encourage health care providers to voluntarily disclose self-discovered evidence of potential fraud, the initial submission of this disclosure must now contain the following information:

1. A complete description of the conduct being disclosed;
2. A description of the provider's internal investigation, or a commitment regarding when it will be completed (completion must be within three months of acceptance into the SDP);
3. An estimate of the damages to the federal health care programs and the methodology used to calculate that figure, or a commitment regarding when the provider will complete such estimate (completion must be within three months of acceptance into the SDP); and
4. A statement of the laws potentially violated by the conduct.

In addition, OIG continues to emphasize the following requirements to the SDP:

1. The provider must fully cooperate with OIG during verification of the matter disclosed.  This includes timely response to OIG's requests for additional information.
2. The provider must make a good faith determination that the matter implicates potential fraud against the federal health care programs, rather than merely an overpayment.

The above information must be included in addition to the Basic Information described in the SDP, the regulation for which can be found by clicking here.

For the full Open Letter to Health Care Providers from OIG, click here.