OIG Self-Disclosure Protocol Change, Stop $100,000+ Penalties

Length: 60 Minutes Expert: Amanda Waesch, Esq.

You are mandated to comply with the OIG’s recently updated Health Care Fraud Self-Disclosure Protocol. And getting it wrong can have dire consequences for your practice. Especially when you consider the recent increase in self-disclosure penalties of up to $100,000 per violation.

According to the Office of the Inspector General’s (OIG), you have an affirmative duty to report potential compliance violations. However, this certainly does NOT mean that you will escape totally unscathed. But, if you know how, you can avoid some of the worst penalties that come with Medicare and Medicaid overpayments, Stark Law violations, and Anti-Kickback Statute infractions.

It all depends on how, when and what you self-disclose. You must know how to voluntarily self-report violations and refund overpayments, and in which circumstances the OIG’s Self Disclosure Protocol applies. The problem is that the self-disclosure and refund process is complicated and frustrating to navigate, but there is help.

That’s where healthcare attorney, Amanda Waesch, Esq., comes in. During her online training session, Amanda will help you determine when to self-disclose potential compliance violations related to billing errors, referral mistakes, Stark violations and Anti-Kickback missteps. Then, she will guide you through how to correctly self-disclose, which can save your practice tens of thousands in government issued penalties.

Here are just a few of the actionable self-disclosure and refund process strategies you’ll receive in this 60-minute online training session:

  • Determine when you must self-report just refunding an overpayment
  • Uncover hidden contract language that can make you run afoul of Stark Law
  • Properly utilize the self-disclosure process to head off official investigations
  • Avoid hiring excluded Medicare and Medicaid employees (and massive OIG penalties!)
  • Establish internal controls for audits using an Audit Elements Table
  • Voluntarily refund overpayments within the due diligence period to stop invasive investigations
  • Add routine Medicare excluded list screening to your workflow to prevent violations
  • Quickly collect all forms and supporting documents the OIG requires for the refund process
  • Prevent mistakes when serving self-pay patients (Hint: You can’t waive fees for services)
  • Take corrective action as soon as necessary to prevent further penalties to your practice
  • Accurately determine who should receive overpayment reports and refunds in different situations
  • Maintain the documents you’ll need to produce during the overpayment investigation process
  • Figure out what questions to ask and to whom before determining your next course of action
  • And so much more…

WARNING: The OIG has made it clear that it is targeting healthcare practices to uncover regulatory violations. Failure to comply with their recently updated Self-Disclosure Protocol can result in significant penalties (that are calculated per incident and can include additional amount multipliers). So, even a small mistake can add up to massive financial penalties for your practice.

When you identify a compliance error, knowing when the OIGs Self-Disclosure Protocol applies isn’t always easy. Then, if you determine that it applies, you must master when, how and what you self-disclose. This is the only way to reduce the massive financial penalties that you can be required to pay.

Get the expert help you need to get the OIG’s Self-Disclosure Protocols right the first time. Don’t risk making mistakes while trying to comply, only to find out later your practice faces serious financial repercussions. Sign up for this expert-led online training today.

P.S. If your practice bills Medicare or Medicaid, has active contracts related to the care you provide, receives even an insignificant benefit from a vendor or provides your patients with referrals, this online training is a must-attend. Don’t wait, access to this training is limited. Register today.

Meet Your Expert

Amanda Waesch
Esq.Healthcare Attorney at Brennan, Manna & Diamond

Amanda Waesch, Esq., is a healthcare Attorney at Brennan, Manna & Diamond.  Her practice focuses on healthcare, employment law and healthcare litigation across the country. She advises healthcare providers including practices and hospitals on reviewing and litigating employment agreements; non-compete agreements and severance agreements. Her work has benefited physicians and administrators in drafting and reviewing employer handbooks, as well as management and training issues.


This webinar provided a great explanation between Stark and Anti-Kickback laws.
Debbie Muzio
Monument Health