OIG refines self-disclosure protocol requirements

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Providers that make appropriate disclosures under the Office of Inspector General's (OIG's) self-disclosure protocol (SDP) will have the benefit of a presumption against imposition of corporate integrity agreements (CIAs) and certification of compliance agreements (CCAs), according to an open letter to health care providers issued by Inspector General Daniel R. Levinson on April 15, 2008. The letter, which refines the requirements for participation in the SDP, "emphasizes the Office of Inspector General's (OIG's) commitment to streamline its internal process for self-disclosure case resolution," the OIG said in a related press release.

The SDP provides guidance to health care providers that voluntarily disclose fraudulent conduct affecting Medicare, Medicaid, and other federally funded health care programs, including compliance issues that the provider believes potentially violate federal criminal, civil, or administrative laws for which exclusion or civil monetary penalties may be imposed.

CIAs and CCAs. According to the open letter, providers that disclose in good faith, cooperate with the OIG, and promptly provide requested information will not be required to enter into CIAs or CCAs with the OIG.

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