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 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.
Outline
- CMS Self-Referral Disclosure Protocol(s)
- OIG Self-Disclosure Protocol
- SRDP vs. SDP
- Best practices for self-disclosure
- Are there alternatives to self-disclosure?
- When to disclose and to whom?
- Potential risks of making a self-disclosure
- Preserving privileged communications
Benefits
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?
Faculty
Samuel C. Cohen, Esq.
Senior Vice President, Health Policy
Curi
Mr. Cohen is Senior Vice President for Health Policy at Curi, a company committed to supporting physicians in medicine,... | Read More
Mr. Cohen is Senior Vice President for Health Policy at Curi, a company committed to supporting physicians in medicine, business, and life. He uses his health policy knowledge and his background as a health care attorney to help physicians and medical practices navigate the opportunities and risks presented by the many changes to the health care environment. He also serves as an in-house educational resource at Curi on a wide range of projects and internal initiatives.
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Anjali N.C. Downs
Member
Epstein Becker and Green
Ms. Downs represents a variety of healthcare and life science organizations including health systems, pharmaceutical... | Read More
Ms. Downs represents a variety of healthcare and life science organizations including health systems, pharmaceutical and medical device manufacturers, pharmacies, clinical laboratories, academic medical centers, and physician group practices. Her practice focuses on fraud and abuse and federal and state regulatory compliance, and she regularly defends a variety of healthcare organizations undergoing government investigations, inquiries and audits.
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Jacob J. Harper
Attorney
Morgan, Lewis & Bockius
Mr. Harper advises stakeholders across the healthcare industry, including hospitals, health systems, large physician... | Read More
Mr. Harper advises stakeholders across the healthcare industry, including hospitals, health systems, large physician group practices, practice management companies, hospices, chain pharmacies, manufacturers, and private equity clients, on an array of healthcare regulatory, transactional and litigation matters. His practice focuses on compliance, fraud and abuse, and reimbursement matters, self-disclosures to and negotiations with OIG and CMS, internal investigations, and provider M&As.
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