Important Things to Know About Self-Disclosure Protocol

Posted by Frank Strafford on December 22, 2015 in Uncategorized,

Important Things to Know About Self-Disclosure Protocol
The Self-Disclosure Protocol is an important step in dealing with excluded individuals in your organization. It’s a tool for healthcare providers to volunteer information and to resolve exclusion issues in a timely manner. Initially released in 1998, the SDP was updated with additional guidelines from the OIG in succeeding years. The latest update was in April of 2013. Below are some important things you should know about the SDP.  

Pick the applicable SDP

A page in the OIG website is dedicated to Self-Disclosure. It offers information and describes the processes of reporting potential medical fraud. You will need to choose the SDP process that is applicable to you: either the Provider Self-Disclosure or the Contractor Self-Disclosure.

The Provider SDP is for healthcare providers and suppliers subject to Civil Monetary Penalties. It gives you the chance to avoid civil and administration investigation-related costs by disclosing evidence of medical fraud. A printable document and a link to self-disclosure online submission is available on this page.

On the other hand, the Contractor SDP is for individuals or businesses who are awarded government contracts and subcontracts that provide Health and Human Services (HHS). This is for contractors who discover potential violations of the False Claims Act and issues of fraud, bribery, and gratuity. To submit a Contractor Self-Disclosure, you can follow the guidelines on this OIG page.

Self-disclosure reports should be submitted properly and not merely reported over the OIG hotline.

Follow the SDP time frame

When you conduct your own internal investigation, you must certify that it will be completed within 90 days of your initial submission. Investigation must be completed before the SDP is submitted, with all findings reported.

Know the specific requirements for disclosure of excluded persons

The SDP must be as specific and detailed as possible. The required details include:

  • the excluded person(s)’s identity/identities
  • the excluded person(s)’s Federal Tax ID number
  • the excluded person(s)’s duties
  • the dates of the excluded person(s)’s employment/contract
  • all background checks done on the excluded person(s) during the time of their employ/contract
  • the provider’s screening process
  • why the individual was hired
  • how the situation came to light
  • the corrective measures taken after the discovery

Compute the minimum multiplier of 1.5 times the singles damages

For organizations who use the SDP, the OIG practices a minimum of 1.5 times the amount paid by the federal health care program compared to about double the amount in a government-initiated investigation. This will keep penalties and exclusion fines going through the roof. However, this multiplier still depends on the exclusion situation, which is why a detailed report is a must.

About Frank Strafford

About Frank Strafford

Related Articles

CMS’ Preclusion List Policy Explained

July 5, 2018

The Centers for Medicare & Medicaid Services (CMS)’ Preclusion List went live Jan. 1, 2019. the Preclusion List is defined as: “A list of providers and prescribers who are precluded from recei...

Infographic: 2017 OIG Exclusions & Penalties

December 20, 2017

In 2017, the HHS Office of the Inspector General (OIG) remained active in detecting Medicare and Medicaid provider violations, resulting in fines or settlements and exclusions from participation. Ther...

Understanding Which Excluded Employees & Entities Are ...

September 19, 2017

When is an Excluded Individual or Entity Problematic? According to federal law, the OIG is legally permitted to enforce CMP (Civil Monetary Penalties) upon any individual or entity which breaches the...

Understanding OIG Exclusions

OIG Exclusions Screening Process

Exclusion FAQS

Quick OIG Exclusion Basics

Employing Excluded Individuals

Consequences to Employing an Excluded Individual

OIG Compliance Law

Laws and Publications on OIG Compliance

More Compliance Resources

Our Culture

We build the best, so you can perform at your best.

Trusted for Good Reason

  • ✓ Guaranteed accurate
  • ✓ Certified Secure
  • ✓ Audit Proof
  • ✓ Feature-rich reporting
  • ✓ Round the clock real-time-data
  • ✓ Processing fully automated

Security First

  • ✓ Cloud hosted
  • ✓ Encrypted data
  • ✓ Real-time backups

Trusted for Accuracy

  • ✓ Physical security
  • ✓ Restricted access
  • ✓ Single sign-on
  • ✓ Password security
  • ✓ Certified secure
  • ✓ Cross checking

HEALTHCARE ESTABLISHMENTS NATIONWIDE COUNT ON STREAMLINE VERIFY

5

60%

Average workload reduction by implementing the Streamline Verify program

5

10K

Establishments trust Streamline Verify nationwide

5

2011

Serving the healthcare industry’s unique compliance needs since 2011

5

24X

Setting standards with hourly synchronization to primary source data