What Are the Benefits of Self-disclosure?
There are several benefits of self-disclosure. When a healthcare provider actually enters a self-disclosure protocol and follows the regulations as written, one of the primary benefits is the potential to minimize the penalties associated with an overpayment, a False Claim Act, etc.
One, the government has said they’re going to try to minimize those fines in comparison to what would be a normal fine under a False Claim settlement.
The second would be the integrity obligations. A lot of providers are familiar with Corporate Integrity Agreement obligations. That is something that the government has pledged for a provider that comes forward and self-discloses in an honest, forthright, proactive manner. Those Corporate Integrity obligations would really be minimized in that fashion.
And the third would be potential exclusion, which would be for the worst of healthcare offenders. Fraud, actually, could have that sanction. Under self-disclosure protocol, that is not going to happen.