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OIG and CMS Voluntary Self Disclosures: Risks and Rewards of Self-Reporting

Leveraging Tools for Resolving Stark Law or Anti-Kickback Statute Violations

Recording of a 90-minute CLE video 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 Wednesday, March 10, 2021

Recorded event now available

or call 1-800-926-7926

This CLE course will guide healthcare counsel on the OIG's Self-Disclosure Protocol (SDP) and settlements under CMS' Self-Referral Disclosure Protocol (SRDP). The panel will also outline guidance for evaluating the risks and rewards of disclosing potential violations.


Counsel to healthcare providers must understand these and other potential tools for resolving Stark Law or Anti-Kickback Statute violations, with each pathway presenting its own advantages and disadvantages.

Listen as our authoritative panel of healthcare attorneys explains the pros, cons, and procedural steps for disclosing under OIG's SDP or CMS' SRDP. The panel will discuss effective approaches for evaluating whether to self-report violations and for achieving favorable outcomes.



  1. CMS Self-Referral Disclosure Protocol(s)
  2. OIG Self-Disclosure Protocol
  3. SRDP vs. SDP
  4. Best practices for self-disclosure
    1. Are there alternatives to self-disclosure?
    2. When to disclose and to whom?
    3. Potential risks of making a self-disclosure
    4. Preserving privileged communications


The panel will review these and other key issues:

  • What factors should healthcare providers consider when determining whether and when a potential Stark law or AKS violation should be disclosed?
  • Which vehicle should healthcare providers use when making a self-disclosure--SDP vs. SRDP?
  • What are best practices for healthcare providers and their counsel when preparing the SDP or SRDP disclosure submission?


Cohen, Samuel C.
Samuel C. Cohen, Esq.

Senior Vice President, Health Policy

Mr. Cohen is Senior Vice President for Health Policy at Curi, a company committed to supporting physicians in medicine,...  |  Read More

Downs, Anjali
Anjali N.C. Downs

Epstein Becker and Green

Ms. Downs represents a variety of healthcare and life science organizations including health systems, pharmaceutical...  |  Read More

Harper, Jacob
Jacob J. Harper

Morgan, Lewis & Bockius

Mr. Harper advises stakeholders across the healthcare industry, including hospitals, health systems, large physician...  |  Read More

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