The Provider Self Disclosure Protocol (SDP) and the OIG- Compliance: Self - Reporting to OIG - When should this happen and how to do it?

Why Should You Attend:

The Self Disclosure Protocol has been in place for some time, there is still significant confusion about when to report and when not to self-report. The guidelines for reporting will be reviewed along with some areas that require extra attention. The settlements for failure to disclose are significant and often onerous. The process used for self-discloser is also reviewed as incorrect submission or submission through the incorrect channels can create more difficulties. This course will provide an overview of what an organization should consider when deciding to self-report and areas to examine to reduce the risk of need for self-reporting .

The release of the revised SDP offers new incentives for facilities to self-report, but also grants greater enforcement sanctions to the Office of the Inspector General (OIG). The Department of Health and Human Services (HHS) believes that there are both legal and ethical standards that require entities to use a self-report system.

This webinar will acquaint attendees with:

• The framework of the revised SDP
• The process and procedures for self-reporting
• The advantages and disadvantages of using the SDP illustrated with examples
• The mechanics of filing an SDP
• The risks of not self-reporting
• The use of an SDP to enhance your compliance program

The program will also review challenges faced by the OIG in dealing with whistle-blowers and how this may impact self-disclosure.

Areas Covered in the Webinar:

• Is disclosure required? HHS says that often there is a legal duty or ethical duty to report violations.
• The better question: Is there an advantage to self-reported disclosure?
• Creates a presumption that a good, solid compliance program is in place
• Can reduce monetary penalties
• Provides flexibility in the return of any overcharges
• Speeds up case resolution and management
• Avoids corporate integrity agreements
• What if I do not self-report, will things go hard on my facility?
• Who can use the SDP?
• What conduct or actions fall under SDP?
• What conduct does not fall under SDP?
• What must be submitted if a facility self-reports general violations?
• What must be submitted in a case of false billing?
• What must be submitted in a case involving an excluded person?
• Eleven elements required.
• Resolution of SDP matters.

Who Will Benefit: This webinar will provide valuable assistance to decision-makers in nursing homes, SNFs, medical offices, practice groups, hospitals, academic medical centers, insurers, business associates (shredding, data storage, systems vendors, billing services, etc.), such as:

• Compliance directors
• CEOs
• CFOs
• Administrators
• Nursing managers
• IT managers
• Chief information officers
• Health information managers
• Healthcare counsels/lawyers
• Office managers
• Contract managers

Laura S Hargraves
Independent Business Owner, Bridging Documentation

Laura S Hargraves, MS CCC- SLP RAC-CT, has been working in all aspects of the healthcare industry for the past 30 years. Ms. Hargraves has been providing compliance and oversight of documentation to meeting changing guidelines during this period. She has a background in education, which helps her maximize her ability to communicate these changes to the various professionals that she works with. She is an expert in documentation/compliance/audits and reviews. Ms. Hargraves is also a professional presenter on topics related to Medicare, MDS 3.0, and documentation.

Topic Background:

In April of 2013, the Office of the Inspector General (OIG) of the United States Department of Health and Human Services issued new procedures called the SDP for facilities to self-report various violations. Knowledge of these procedures supports your team’s compliance goals. If there is a need for self-reporting, it indicates that your team’s compliance program is working.

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