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’ commanding knowledge of the False Claims Act, Anti-Kickback Statute, and Stark Law safeguards... | Read More
Ms. Downs’ commanding knowledge of the False Claims Act, Anti-Kickback Statute, and Stark Law safeguards healthcare clients’ products, services, and ensures operational success. Clients, which range from providers to device manufacturers and ambulatory centers, depend on her in-depth understanding of the fraud and abuse laws and what triggers government authorities to take exception. As regulatory counsel, Ms. Downs aligns clients’ risk tolerance with commercial opportunities to create a path forward. As value-based care expands, she is preparing clients to meet related challenges on fraud and abuse laws and the interactions by and between healthcare referral sources.
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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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