Compliance/Enforcement - Compliance With Self Disclosure Protocols

The use of various state and federal enforcement agency's voluntary self disclosure protocols is becoming an increasingly integral part of an effective compliance plan, especially in the wake of the new reporting and return of overpayment requirement contained in the Patient Protection and Affordable Care Act (PPACA). These include:

  • The New York State Office of the Medicaid Inspector General's Self Disclosure Protocol;
  • The HHS Office of Inspector General’s Self Disclosure Protocol; and
  • The CMS Self-Referral Disclosure Protocol for potential Stark violations.

Deciding whether to disclose, which agency to disclose to, and formulating a disclosure entails significant strategic considerations with serious financial implications. Hinman Straub’s fraud and abuse group can assist you in making the right decisions and preparing a disclosure strategy and disclosure document designed to mitigate or eliminate potential liability.

Practice Area Professionals

Sean Doolan

Mara Ginsberg

Raymond Kolarsey

Philip Murphy

Stephanie Piel

Jennie Shufelt

To learn more about our Health services, please contact Raymond Kolarsey.