Articles and Blogs

self-disclosure

A New Option for Grant Noncompliance: OIG Releases Grantee Self-Disclosure Program

[08/16/19]

Posted on August 16, 2019 in Health Law News

Published by: Hall Render

On July 11, 2019, the Office of Inspector General (“OIG”) for the U.S. Department of Health and Human Services (“HHS”) released the new Grant Self-Disclosure Program Guidance (“Grant Guidance”) for HHS grant recipients and subrecipients. Through the Grant Guidance, OIG provides new self-reporting options for HHS grant recipients and subrecipients who determine that they... READ MORE

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Stressful or Streamlined? CMS’s New SRDP Disclosure Form Presents New Challenges for Providers

[04/14/17]

Posted on April 14, 2017 in Health Law News

Published by: Hall Render

The Centers for Medicare & Medicaid Services (“CMS”) recently updated its Voluntary Self-Referral Disclosure Protocol (“SRDP”) when it posted a new form to be used as part of the SRDP process (“SRDP Form”). According to CMS, the SRDP Form is an attempt to “streamline and simplify” the SRDP process. CMS originally proposed the new SRDP... READ MORE

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Self-Disclosure, the Public Disclosure Bar and the FCA – Uncertainty, Circuit by Circuit

[02/11/15]

Posted on February 11, 2015 in False Claims Act Defense

Written by: David B. Honig

Written by David B. Honig and Ritu Kaur Cooper. On February 3, 2015, the Fourth Circuit Court of Appeals ruled that disclosures to the public officials responsible for managing the subject of a False Claims Act lawsuit did not qualify as “public disclosures” for the purpose of the FCA’s public disclosure bar. US ex rel. Wilson v.... READ MORE

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