The Health Care Policy Blog is a forum for health care policy professionals
and Bloomberg BNA editors to share ideas, raise issues, and network with
Wednesday, June 20, 2012
by James Swann
The OIG is getting set to update the provider
self-disclosure protocol, and it’s looking for help from the public. The June
18 Federal Register featured a notice from the OIG asking for recommendations on
how best to revise the protocol, which was originally published by the OIG in
1998. Several attorneys have told me that providers are eager to get some
clarification on how long the entire self-disclosure process should last, from
identifying a potential violation to reaching a resolution with the OIG.
The original protocol laid out steps for providers to self-disclose
any potential fraud involving Medicare or Medicaid, and the OIG has revised the
document three times since 1998. The most recent revision, in 2009, said the
OIG would no longer accept self-disclosures involving only Stark law
violations. CMS took on the job of accepting Stark law self-disclosures in
to post a comment.
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