I spoke with OIG's Tony Maida this week about their recently revised self-disclosure protocol, and he told me the idea behind the revision was to increase transparency for providers. He told me "it's helpful to have our expectations more clearly defined for providers on the front of the SDP." Maida also told me the revised SDP included guidance on common OIG practices that had never been articulated before, such as requiring a minimum multiplier of 1.5 times the single damages.

The OIG's original SDP was released in 1998, and OIG has issued three open letters since then, supplementing the protocol. Maida told me there was strong support for incorporating the original SDP and the open letters into one document. Since its release, the SDP has been used to resolve more than 800 disclosures, OIG said.

I also spoke with Larry Freedman, an attorney with Patton Boggs, and he said the revised SDP is an indication that "providers do want some clear expecation of what their involvement with the SDP will entail."