decisionhealth Newsletters, Answer Books - 2009 Issue 3 (March)
Voluntary Disclosure Program / After Disclosure - What OIG Expects / Internal Investigation Guidelines
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Article Overview
This article explains the broad components of an internal investigation report prepared for OIG in connection with a voluntary disclosure under the Self-Disclosure Protocol. It is aimed at compliance, legal, audit, and health care operations staff who need to understand the expected scope of fact gathering, documentation, follow-up actions, and certification. The discussion focuses on the types of information the report should address, including the scope of the matter, discovery and response, documentation reviewed, corrective actions, related entities, and required certifications.
Why This Topic Matters
Understanding the expected report framework helps organizations prepare a complete disclosure package and organize the internal review needed to support communication with the OIG.
Article Sections
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Nature and extent of the improper or illegal practice
This section outlines the broad categories of information expected in a report about the scope, duration, impact, and personnel involvement in a disclosed matter.
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Discovery and response to the matter
This section addresses how the issue was identified, the internal review process, documentation reviewed, corrective actions, and related organizational responses.
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Certification
This section covers the requirement for an authorized certification accompanying the internal investigation report.
What You Will Learn
- What OIG expects an internal investigation report to generally cover
- How disclosure reports are organized around scope, discovery, response, and certification
- Which categories of supporting information are typically documented in a self-disclosure review
- How related entities, personnel actions, and follow-up measures fit into the report framework
Who Should Read This
- Compliance officers
- Health care attorneys
- Audit and investigation teams
- Revenue integrity professionals
- Health care administrators
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