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Healthcare Providers and Voluntary Disclosures: Evaluating If, When, and How to Report to CMS, DOJ, or OIG

Recording of a 90-minute CLE webinar with Q&A

This program is included with the Strafford CLE Pass. Click for more information.
This program is included with the Strafford All-Access Pass. Click for more information.

Conducted on Tuesday, October 13, 2020

Recorded event now available

or call 1-800-926-7926

This CLE course will guide healthcare counsel on voluntary disclosure. The panel will also discuss evaluating the risks and rewards of disclosing potential violations. The panel will outline strategies for healthcare providers and counsel in deciding if, what, when, and how to report potential violations.


Enforcement against healthcare fraud and abuse continues to be a top priority. Violations can involve anything from simple error to intentional conduct.

Healthcare providers must evaluate their potential violations to determine whether, how, and to whom to report. Providers should have in place a whistleblower process so they can investigate areas of concern and determine if there are violations that require self-disclosure. Counsel to healthcare providers must understand the potential tools for resolving Stark Law or Anti-Kickback Statute violations. The options have never been so varied as they are now, with each pathway presenting advantages and disadvantages.

Listen as our authoritative panel of healthcare attorneys examines the revised OIG self-disclosure protocol, discusses how to report Stark Law and other violations, and offers best practices for both addressing potential violations and using OIG protocol.



  1. Practical and strategic considerations and best practices
    1. Conducting the investigation
    2. Handling potential whistleblowers
    3. Determining what to disclose and how
    4. Dealing with missing evidence and witnesses
    5. How far back?
    6. Internal communications and informing the board
  2. Voluntary disclosure options
    1. OIG self-disclosure protocol
    2. Department of Justice
    3. Medicare contractors
    4. State voluntary disclosure protocols
    5. Stark Law and self-disclosure
    6. Self-disclosure case studies


The panel will review these and other key questions:

  • What factors should healthcare providers consider when determining whether and when to disclose a potential Stark Law or AKS violation?
  • What options do healthcare providers have for voluntary disclosure?
  • If a healthcare provider reaches settlement with the Department of Justice, what impact will that settlement have on the provider's dealings with OIG? Or with CMS?


Michael, Jennifer
Jennifer E. Michael

Epstein Becker & Green

Ms. Michael’s practice focuses on fraud and abuse and federal and state regulatory compliance. Before joining the...  |  Read More

Oppenheim, Charles
Charles B. Oppenheim

Hooper Lundy & Bookman

Mr. Oppenheim’s practice includes all aspects of transactional, operational and regulatory healthcare law,...  |  Read More

Tamulis, Julia
Julia Tamulis

Bass Berry & Sims

Ms. Tamulis focuses her practice on counseling a diverse range of clients on complex healthcare regulatory issues...  |  Read More

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