decisionhealth Newsletters, Answer Books - 2009 Issue 3 (March)
OIG Model Compliance Plan / Step 6 - Respond to Detected Violations / Provider Self-Disclosure Protocol
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Article Overview
This article discusses how the OIG Provider Self-Disclosure Protocol fits into compliance programs, voluntary disclosure of potential fraud or abuse, and audit planning. It is aimed at providers, compliance officers, and healthcare organizations that want a general understanding of the protocol, its relationship to corporate integrity agreements, and its use as a model for internal audits and self-assessments. The article also covers the broad elements of sampling and documentation referenced in the protocol and points readers to the OIG and Federal Register sources for further guidance.
Why This Topic Matters
Understanding the Provider Self-Disclosure Protocol can help organizations evaluate whether the article is relevant to compliance, self-reporting, and internal audit processes. It is especially useful for teams involved in responding to detected violations and planning investigations or self-assessments.
Article Sections
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Provider Self-Disclosure Protocol and voluntary disclosure
Introduces the OIG self-disclosure process and its role in addressing potential fraud or abuse concerns within a healthcare organization. It also places the protocol in the context of federal health care programs and response to detected issues.
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Potential effects on resolution and corporate integrity agreements
Summarizes the article’s discussion of how self-disclosure may affect the way matters are resolved and how corporate integrity agreements may be considered in that process. It also notes the broader compliance context described in the article.
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Using the protocol for audits and self-assessments
Covers how the protocol may be used as a model for baseline audits, investigative planning, and internal self-assessment activities. The section also addresses the importance of documenting audit-related elements and following the protocol’s general format.
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Sampling guidance and documentation
Describes the article’s discussion of sample selection and related audit documentation concepts drawn from the protocol. It focuses on the general sampling framework and the need for clear internal documentation.
What You Will Learn
- How the OIG Provider Self-Disclosure Protocol relates to compliance response efforts
- Why organizations may consider voluntary self-disclosure when potential irregularities are found
- How the protocol is used as a general model for audit and self-assessment planning
- What broad sampling and documentation topics are highlighted in the protocol
Who Should Read This
- Healthcare providers
- Compliance officers
- Healthcare administrators
- Audit and investigative staff
- Healthcare legal counsel
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