Voluntary Disclosure Program / Six More Reasons to Self-Disclose

Why This Topic Matters

Self-disclosure decisions can shape how a healthcare organization responds to compliance concerns, interacts with government investigators, and manages risk. This article helps readers understand the high-level factors that make the OIG disclosure process relevant to organizational compliance strategy.

Article Sections

1. 1) Control the information

   This section addresses the initial advantages of managing communications within the voluntary disclosure process and preparing supporting documentation before broader government involvement.

2. 2) Minimize expense and disruption to your organization

   This section focuses on the organizational impact of internal review and the general goal of limiting disruption and costs associated with investigations.

3. 3) Mitigate penalties for good faith

   This section discusses the broader compliance and enforcement considerations that may be associated with cooperation and trustworthiness in the disclosure context.

4. 4) Reduce the risks of a Qui Tam

   This section covers whistleblower-related risk in the context of healthcare fraud and abuse concerns and the timing of disclosure relative to potential legal action.

5. 5) Reduce Criminal Prosecution

   This section reviews general federal prosecution guidance, corporate compliance considerations, and the role of cooperation in criminal enforcement risk.

6. 6) Reduce the chances of permanent exclusion

   This section addresses the potential effect of disclosure on exclusion-related consequences and the importance of program trustworthiness in the compliance setting.