On November 8, 2021, the U.S. Department of Health and Human Services (HHS) Office of Inspector General (OIG) amended its Health Care Fraud Self-Disclosure Protocol (SDP). Among other things, OIG clarified that damages estimates must include an itemization of damages for each Federal health care program, as well as total damages for all Federal health care programs. In addition, OIG confirmed that organizations operating under Corporate Integrity Agreements (CIA) may also use the SDP if they reference such and send a copy of the disclosure to their OIG monitor.
We are pleased to enclose our three-part series on how to implement the SDP – in a practical and pragmatic way.
We invite you to reach out to continue the conversation at any time on voluntary self-disclosures and CIA-related Independent Review Organization matters.