decisionhealth Newsletters, Answer Books - 2009 Issue 3 (March)
Voluntary Disclosure Program / OIG - No Guarantees to Providers Who Self-Disclose
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Article Overview
This article discusses the OIG voluntary disclosure program and the practical concerns raised by providers, attorneys, and enforcement agencies when a provider considers self-disclosure. It focuses on the lack of guarantees around outcomes, the range of possible enforcement responses, and why the topic matters to compliance teams, legal counsel, and healthcare organizations evaluating disclosure decisions.
Why This Topic Matters
It helps readers understand the general enforcement and compliance risks associated with self-disclosure in healthcare, including the possibility that a disclosure may lead to broader investigation or action by multiple authorities.
What You Will Learn
- Why providers and attorneys may be cautious about self-disclosure under the OIG program
- What general types of enforcement or legal exposure can arise after disclosure
- Why early communication with investigators is discussed in the context of disclosure programs
- How the article frames uncertainty in the voluntary disclosure process
Who Should Read This
- Healthcare providers
- Compliance officers
- Healthcare attorneys
- Practice managers
- Revenue cycle and risk management professionals
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