OIG Releases Revised Provider Self-Disclosure Protocol

On April 17, 2013, the U.S. Department of Health and Human Services (HHS) Office of Inspector General (OIG) released a revised Provider Self-Disclosure Protocol (SDP), which offers two attractive incentives to providers to self-disclose: 1) reasonable assurance that their financial exposure will be limited to 1.5 times the single damages, and 2) a presumption against imposition of a corporate integrity agreement (CIA) by OIG. In addition, the new SDP addresses the historical problem the lengthy review process for SDPs and acknowledges the dilemma providers face with respect day window to return overpayments. The new SDP supersedes and replaces the original SDP, published in the Federal Register in 1998, and three open letters issued by the OIG.

About the Author

Suzanne Dallas Castaldo, JD, is a certified Healthcare Compliance Professional (CHC, CHPC), qualified in the development, implementation, and evaluation of compliance programs for the health care industry. She has assisted a variety of health care providers including hospitals, physician practice groups, skilled nursing facilities, clinical laboratories, managed care organizations, and pharmacies.