Health Care Fraud Self-Disclosure Protocol: Navigating Amended Guidance for Providers and Suppliers
Recording of a 90-minute CLE video webinar with Q&A
This CLE course will guide health care counsel on the recent changes to the Department of Health and Human Services (HHS) Office of the Inspector General's (OIG) Self-Disclosure Protocol. The panel will also briefly discuss the CMS Self-Referral Disclosure Protocol, which has not changed since 2017. The panel will offer best practices for evaluating the advantages and disadvantages of disclosing potential violations and navigating the new guidance.
Outline
- Evaluating whether to disclose and options for disclosures
- This topic will also cover understanding when to use OIG's Self-Disclosure Protocol versus CMS' Self-Referral Disclosure Protocol
- OIG's Self-Disclosure Protocol and the amended guidance
- Best practices for self-disclosures and navigating the new guidance
Benefits
The panel will review these and other key issues:
- What changes were made to the OIG's Self-Disclosure Protocol?
- Which avenue should healthcare providers use when making a self-disclosure?
- What are best practices for healthcare providers and their counsel when preparing OIG Self-Disclosure Protocol or CMS Self-Referral Disclosure Protocol disclosure submission?
Faculty
T. Jeffrey Fitzgerald
Shareholder
Polsinelli
Mr. Fitzgerald’s practice focuses on defending healthcare clients in healthcare fraud investigations. He believes... | Read More
Mr. Fitzgerald’s practice focuses on defending healthcare clients in healthcare fraud investigations. He believes effective strategies for successfully defending investigations include the rigorous exploration of the facts and a detailed analysis of the applicable regulations. Mr. Fitzgerald represents healthcare providers in disputes with federal and state licensure bodies, professional licensure boards, and other regulators and law enforcement agencies. He also assists healthcare companies that have proactively discovered potential compliance issues. Mr. Fitzgerald uses his experience in resolving investigations to develop practical solutions that bring finality and risk reduction to compliance problems.
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Heidi A. Sorensen
Counsel
Alston & Bird
Ms. Sorensen builds on her previous experience at the Office of Counsel to the Inspector General of the Department of... | Read More
Ms. Sorensen builds on her previous experience at the Office of Counsel to the Inspector General of the Department of HHS to assist clients with health care regulatory, compliance, and fraud and abuse matters. She focuses her practice on health care fraud and abuse and compliance matters, including the Anti-Kickback Statute. Ms. Sorensen assists clients in False Claims Act investigations, negotiating FCA settlements and corporate integrity agreements, and matters that fall under the Civil Monetary Penalties Law and OIG exclusion authorities. She helps clients develop compliance programs and implement corporate integrity agreements. Ms. Sorensen previously served as chief of the Administrative and Civil Remedies Branch in the Office of Counsel to the Inspector General (OCIG) at HHS. She served as the OCIG’s coordinator for both the Provider Self-Disclosure Protocol and the Physicians at Teaching Hospitals national project and also served the OCIG as senior counsel and deputy branch chief.
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Rachel E. Yount
Attorney
Mintz Levin Cohn Ferris Glovsky and Popeo
Ms. Yount's practice involves a variety of regulatory, compliance, and transactional matters for a broad range... | Read More
Ms. Yount's practice involves a variety of regulatory, compliance, and transactional matters for a broad range clients across the health care industry, including health care systems, managed care organizations, pharmacies, device and pharmaceutical manufacturers, long-term and post-acute care providers, and private equity firms investing in the health care industry.
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