OIG Releases Updated Provider Self-Disclosure Protocol
released updated provider self-disclosure protocol, which is entirely revised from the SDP published in 1998.
The protocol instructs healthcare providers what to do if they discover actions violate federal fraud and abuse laws.
Updating the SDP has been a process. OIG issued open letters to healthcare providers in 2006, 2008 and 2009 for suggestions on how to improve the SDP. It also solicited comments on the SDP in June 2012, receiving "numerous helpful comments" from the public.
"Since the original publication [of the SDP], we identified areas where additional guidance would be beneficial to the healthcare community and would improve the efficient resolution of SDP matters," the OIG wrote.
Among the changes since 2008, the OIG narrowed the SDP's scope regarding the physician self-referral law, established a minimum settlement amount and established guidelines for providers' initial submissions in the disclosure process.
The OIG said some of the most common issues providers disclose include:
• Billing for items or services furnished by excluded individuals.
• Evaluation & management services and DRG upcoding.
• Duplicate billing.
• Alteration or falsification of records.
• Kickbacks and Stark Law violations.
To date, since SDP was established in 1998, monetary recoveries have exceeded $280 million.
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