OIG Announces Update to Self-Reporting Protocol for Providers

OIG announced on their website yesterday that they were updating their self-reporting protocol for Medicaid providers.

Here is what is said with a PDF copy of the protocol below.

The OIG has updated the protocol providers use to voluntarily disclose mistakes to the agency when correcting claims for Medicaid and other Texas Health and Human Services (HHS) programs. The self-report process allows the OIG to develop partnerships with providers while reducing fraud, waste and abuse.

Providers must cooperate in good faith with the OIG to participate in the self-disclosure process. This includes submitting all necessary information, communicating through a consistent point of contact, and responding to requests for additional information. These efforts show the provider recognizes the error and is working with the agency to resolve the mistake.

The new self-report protocol also offers providers several additional benefits that occur at the discretion of the OIG. These changes can reduce administrative and financial obligations stemming from the error. Specifically, the protocol provides:

    • A suspension of the obligation to report overpayments by the specified deadline under Section 1128J(d) of the Affordable Care Act, so long as the submission is timely.
    • A reduction in the likelihood of a permissive exclusion.
    • A lower multiplier on single damages than would be required in resolving an OIG-initiated investigation.
    • Less severe or restrictive administrative action or sanctions.

The update also provides information on calculating damages when an employee whose services or items are not billed separately is excluded from participating in Texas Health and Human Services programs. Exclusions apply to providers and front office staff and can occur for several reasons, including Medicaid fraud convictions, patient abuse, and licensing issues. Providers can access a list of excluded providers on the OIG website.

Mandatory information is listed in the protocol for providers deciding to self-disclose through a letter to the agency. The required details include contact and business information, a statement of what laws or regulations were violated, what HHS programs were impacted, and what corrective actions have been taken. Providers can also use the online reporting tool to begin the self-report process.


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