OIG and CMS Voluntary Self Disclosures: Weighing the Risks and Rewards of Self Reporting

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

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

Conducted on Thursday, September 15, 2016

Recorded event now available

or call 1-800-926-7926
Program Materials

This CLE webinar will provide guidance to 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. The options have never been so varied as they are now, with each pathway presenting its own advantages and disadvantages.

Then, of course, there is the challenge of navigating these pathways and their peculiar requirements and measures.

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, including CMS’s proposed revisions to its Self-Referral Disclosure Form
  2. OIG’s 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 the best practices for healthcare providers and their counsel when preparing the SDP or SRDP disclosure submission?


Cohen, Samuel
Samuel C. Cohen

Arent Fox

Mr. Cohen's practice focuses on counseling clients regarding compliance with health care fraud and abuse laws, with...  |  Read More

Anjali N.C. Downs, Esq.
Anjali N.C. Downs, Esq.

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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