Medicare Compliance & Reimbursement

OIG identifies three distinct benefits of self-reporting.

As part of the newly published “Practical Guidance for Health Care Governing Boards on Compliance Oversight,” the HHS Office of Inspector General (OIG) also stressed the importance of self-identification and self-reporting of compliance problems. 

And as an enticement, the OIG listed in the guide the benefits of self-disclosing compliance problems under the OIG’s Self-Disclosure Protocol:

1. Faster resolution — The average OIG self-disclosure case is resolved in less than one year.

2. Lower payment — The OIG settles most self-disclosure cases for 1.5 times damages, rather than for double or treble damages and penalties available under the False Claims Act.

3. Exclusion release — You can obtain exclusion release as part of a settlement with no Corporate Integrity Agreement (CIA) or other compliance obligations.

Bottom line: The OIG stresses that “providers have legal and ethical obligations to disclose known violations of law occurring within their organizations.” Boards should discuss with management how to handle identification of probable violations, including self-disclosure of such issues to the government, the OIG says.

Resource: For more information on the OIG Self-Disclosure Protocol, visit oig.hhs.gov/compliance/self-disclosure-info.