OIG Compliance and Self-Disclosure

December 09, 2016 | Pamela Youngberg Dickson

Last week, we provided some information to help you determine whether you are properly managing your OIG exclusion checks and connected you to a starting point for running monthly employee and entity checks here. But what do you do when a familiar name pops up on that list? After all, penalties can be harsh.

We’ve found some great resources to help you understand compliance and some things to consider with regard to self-reporting:

• There will be some initial investment in putting a program in place in response to the discovery of a compliance issue, but self-reporting indicates that you have an effective program in place, removing the need for a Corporate Integrity Agreement (CIA).
• Complying with the burden of a CIA is, in itself, very burdensome. As a result, you’ll see reduction in major and unnecessary expenses by self-disclosure.
• While penalties for noncompliance are severe, the OIG had traditionally reduced penalties from three-times the requested reimbursement to one-and-a-half times—and in 2013, formally announced this “break” for entities that self-disclose.
• The self-disclosure process takes about twelve months to complete. If you are on an exclusion list, you may begin the process of reinstatement ninety days before the end of your exclusionary period—typically five years.

The self-disclosure portal is located here, where you’ll also find a listing of recent actions taken by the Office. This eBook, The Ultimate Guide for Exclusion Monitoring, is a great resource for more detailed information.** Any other questions? Drop a note to our sister company Smart-HR at: solutions@smart-hr.com.

*This is intended as general information only. Nothing provided herein is intended as nor should be construed as legal advice. No action should be taken without first contacting a knowledgeable attorney regarding your specific situation.
**Smart-Fill is not affiliated with ProviderTrust and receives no remuneration for this recommendation.


Pamela Youngberg Dickson

Before she came to Smart-Fill, Pamela developed marketing strategy and content for a range of technology start-ups and large-cap enterprises. Outside the office, she's into gardening, renaissance history, the Big Ten, and exploring the great outdoors.