Fast Break: Self-Disclosures

"Oops." It's the word all GCs and compliance officers dread. Mistakes happen, but knowing how to appropriately address and resolve issues of potential non-compliance can avoid making a difficult situation worse. Join us for our next installment of the Fast Break series as we discuss the various self-disclosure protocols offered by CMS and OIG. The session will cover some fundamentals about how each process works, expectations in each protocol, and considerations in making the decision to self-disclose.

Topics Include:

• CMS self-referral disclosure protocol for Stark Law issues
• OIG self-disclosure protocol for anti-kickback and CMP issues
• Considerations in self-disclosure, including alternatives, risks, when to make a disclosure, and preserving privileged communications
• Tips for interfacing with OIG and CMS during the process