Healthcare News & Insights

OIG seeking advice on self-disclosure protocol

If you have an opinion you want to share with the Office of the Inspector General (OIG) on self-disclosure protocols, feel free to add your two cents now.

The OIG published the Provider Self-disclosure Protocol in 1998 to establish a process for healthcare providers to disclose potential fraud involving the federal healthcare programs.

Since then, the OIG has resolved more than 800 disclosures and recovered more than $280 million.

It’s also revised the protocol three times since 1998 when it uncovered additional guidance that would be beneficial to the provider community:

  • In 2006, the OIG announced an initiative to encourage disclosure of conduct creating liability under the OIG’s anti-kickback and physician self-referral law
  • In 2008, the OIG added additional guidance and requirements for protocol submissions to increase efficiency, and
  • In 2009, the OIG announced it would no longer accept disclosure of a matter into the protocol that involved only liability under the physician self-referral law in the absence of a colorable anti-kickback violation, and there would be a minimum $50,000 settlement amount for kickback-related submissions.

Currently, the OIG is seeking comments on how hospitals and providers can self-report possible healthcare fraud. You may submit a comment one of three ways:

  • Electronically — You can submit electronic comments on specific recommendations and proposals through the Federal eRulemaking Portal by clicking here.
  • Regular, express or overnight mail — Written comments can be send to: Kenneth D. Kraft, Office of Inspector General, Department of Health and Human Services, Attention: OIG-1301-N, Room 5541B, Cohen Building, 330 Independence Ave., SW, Washington, DC 20201, and
  • Hand or courier — Comments may also be delivered by hand or courier to the address in the bullet above. If you choose this means of delivery, you’re encouraged to schedule a delivery with a staff member at 202-708-9848, because access to the interior of the Cohen Building isn’t readily available to people without federal government identification.

All submissions must include the agency name and docket number for this Federal Register document. And all comments must be received by Aug. 17, 2012.

  • If we are all forced in to getting a EMR or healthcare CRM I dont see why they cant have the emr companies include some kind of tracking system because we are all going to be putting in our information in to an emr anyway.

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