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The OIG's Updated Self-Disclosure Protocol


The OIG's Updated Self-Disclosure Protocol
$224
Webinar
Product Code - LGA169
Speaker(s): Jonathan L. Diesenhaus, Hogan Lovells US LLP; Eliza Andonova, Hogan Lovells US LLP
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On April 17, 2013, the Office of Inspector General of the Department of Health and Human Services (OIG) released an updated self-disclosure protocol (SDP) that significantly overhauls the process for providers and others to voluntarily disclose and resolve instances of potential fraud involving federal health care programs such as Medicare and Medicaid. The revised SDP adds substantial new guidance on assembling the content included in disclosures and provides greater transparency into the OIG’s process for resolution of disclosed matters. Notably, the SDP for the first time publicly acknowledges how the OIG approaches damages calculations in particular situations and sets minimum settlement amounts for resolving particular disclosed matters.

This program will help participants understand the changes to the SDP process and potential resolutions available for resolving particular disclosed matters. Additionally, attendees will learn to identify issues that those considering making a self disclosure, or those advising clients in whether and when to avail themselves of the SDP, should consider before submitting the self-disclosure to the OIG.

Educational Objectives:

• Understand the self-disclosure process.
• Identify the changes in the self-disclosure protocol.
• Learn the issues to be considered in deciding whether and when to make a self-disclosure.

Who would benefit most from attending the program?

Attorneys who are advising clients on the self-disclosure protocol and those in position to decide whether to report misconduct through the OIG’s self-disclosure protocol.

Program Level: Intermediate

Credit Available: CLE. For more information, please click on the “CLE Credit” tab.

Jonathan L. Diesenhaus, Hogan Lovells US LLP; Eliza Andonova, Hogan Lovells US LLP

Jonathan L. Diesenhaus, Hogan Lovells LLP
Jonathan L. Diesenhaus is a partner with Hogan Lovells US LLP, where he focuses on health care fraud and abuse litigation and counseling, federal and state False Claims Act litigation, and white collar criminal defense. Previously, he served as a senior trial counsel in the Civil Division of the U.S. Department of Justice (DOJ) in Washington, D.C. From 1998 to 2005, he handled civil fraud and False Claims Act matters. Mr. Diesenhaus was designated an authority in the Stark Law, the health care Antikickback Statute, and the viability of claims under the False Claims Act as a remedy for unlawful marketing practices, including violations of the Food, Drug, and Cosmetics Act. Throughout his tenure at the department, he also worked closely with the Department of Health and Human Services (HHS), Office of the Inspector General, and Office of General Counsel to interpret and enforce the Antikickback Statute and the Stark Law, and he was principal author of the DOJ's comments on various regulations and advisory opinions that HHS issued under those statutes.

Mr. Diesenhaus earned a J.D. from the University of California, Berkeley Boalt Hall School of Law and is licensed to practice in the District of Columbia and Colorado.

Eliza Andonova, Hogan Lovells LLP
Eliza Andonova is a senior associate at Hogan Lovells US LLP and her practice focuses on healthcare issues, with an emphasis on fraud and abuse counseling and litigation. She advises healthcare providers and pharmaceutical and device manufacturers on potential fraud and abuse and other regulatory concerns, including those arising the under the Anti-Kickback Statute, False Claims Act, and the Stark self-referral prohibitions. Ms. Andonova frequently assists with the development, implementation and review of corporate compliance programs, policies and procedures. She has extensive experience defending pharmaceutical and medical device clients in litigation and government investigations, including exclusion litigation and settlement negotiations with the Office of Inspector General of the U.S. Department of Health and Human Services. She also has worked with clients on improving their internal compliance programs.

Ms. Andonova earned a J.D. from Cornell Law School and is licensed to practice in the District of Columbia and the Commonwealth of Virginia.

This program’s CLE-credit eligibility varies by state. Bloomberg BNA is an accredited provider in the states of New York*, California, Pennsylvania, Texas and Virginia, and most other jurisdictions grant CLE credit on a per-program basis. At this time, Bloomberg BNA does not apply directly to the states of Florida, Rhode Island, Montana and Hawaii although credit is usually available for attorneys who wish to apply individually. Additionally, the following states currently do not grant credit for Bloomberg BNA distance learning programming: Arkansas, Ohio, Nebraska, and Delaware. All requests are subject to approval once the live webinar has taken place or the customer has viewed the OnDemand version. Please contact the Bloomberg BNA accreditations desk if you have specific questions that have not been addressed.

If you have further questions regarding a specific state or how to file for CLE credit, please contact Bloomberg BNA customer service at 800-372-1033 and ask to speak to the CLE Accreditation Coordinator.

Hardship Policy
Bloomberg BNA offers a hardship policy for attorneys earning less than $50,000 per year. If an attorney wishes to take advantage of this option, he or she must contact Bloomberg BNA directly. For attorneys who are unemployed or earning less than $35,000 per year, a full discount off the price of the program will be awarded upon written proof of hardship. Attorneys earning between $35,000 and $50,000 per year will receive a 50% discount off the price of the program. Any attorney working in the public service sector also qualifies for a special price. If you have further questions regarding the hardship policy or seek additional information, please contact Bloomberg BNA customer service at 800-372-1033 and ask to speak to the CLE Accreditations Coordinator, or email us at accreditations@bna.com.

Questions
For more information about Mandatory or Minimum Continuing Legal Education (MCLE) requirements, visit the American Bar Association website at http://www.abanet.org/cle/mandatory.html.

*Bloomberg BNA is an accredited provider in New York for experienced attorneys only.