CHA News

OIG Revises Self-Disclosure Protocol

New guidance addresses 60-day overpayment rule proposed by CMS

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The U.S. Office of Inspector General (OIG) today issued a revised guidance to its provider Self-Disclosure Protocol (SDP). The guidance addresses a range of issues for providers who wish to voluntarily disclose self-discovered evidence of potential fraud, including conduct eligible (and ineligible) for the SDP, disclosure requirements, calculating damages and reporting potential anti-kickback statute violations. The new protocol also suspends a 60-day overpayment rule (see CHA’s comments) proposed by the Centers for Medicare & Medicaid Services (CMS). The OIG said it would provide further SDP guidance once CMS releases its final rule on the 60-day overpayment issue. The revised SDP is available at http://oig.hhs.gov/compliance/self-disclosure-info/files/Provider-Self-Disclosure-Protocol.pdf.