Guidelines for Self-Disclosure: Who, What, How, and When?
The following article was published by “Compliance Today.”
Voluntary self-disclosure of a potential overpayment matter or other non-compliant activity may be mandated by law under certain circumstances and/or potentially be appropriate (if not mandated by law) and offer protections too significant to pass up under the circumstances. Self-disclosures can be a useful option for not only overpayment matters, but a wide array of non-compliant activity, including misconduct and substantial violations of law. However, in considering the options for self-disclosure, a provider or supplier should carefully evaluate the relevant pros and cons of each situation, as well as the most appropriate agency entry point for the self-disclosure. Careful consideration may lead to the conclusion that self-disclosure may not even be warranted, but this determination should be made after a careful and thorough analysis, taking into consideration, best practices, the risk of non-disclosure and, ultimately, the advice of experienced counsel for these matters.
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