With increased governmental focus on potential fraud and abuse, consternation over the pros and cons of voluntary disclosure has increased substantially for healthcare providers and payors.
For healthcare organizations that voluntarily disclose overpayments, OIG continues to indicate that criminal prosecution is less likely and the government is also less likely to pursue whistleblower allegations subsequent to the disclosure. However, these broad guidelines are not absolute and as such, do not preclude the initiation of a ZPIC audit as a result of the disclosure. They also do not preclude civil or criminal prosecution or the use of voluntarily disclosed information as evidence against the organization.
When analyzing an event to determine whether voluntary disclosure is the appropriate course of action, a healthcare organization must give careful consideration to the potential ramifications of the decision.
Join us for a pragmatic educational webinar with experts on voluntary disclosure from Sonnenschein Nath & Rosenthal LLP. The presenters will focus on the potential benefits and risks and provide guidance on making the often-difficult decision to voluntarily disclose.
Key learning points of the session will focus on:
- The additional risks created by the Government’s increased focus on fraud and abuse
- The legal ramifications and potential brand and revenue risks of whistleblower allegations
- Conducting effective internal investigations
- Making the decision to self-disclose – what are the key indicators
- Recommendations for establishing a disclosure program that is compliant with current regulations
Who Should Attend
- CFO and CEOs
- Chief Compliance Officer
- Chief Risk Officers
- Director of Regulatory Affairs
- Legal/Regulatory Counsel
- VP/Director of Revenue Cycle
About the Presenters
Gadi Weinreich is a partner in Sonnenschein’s Health Care Group and a member of the Firm’s Executive Committee. He has been recognized by Chambers USA, ExpertGuides, Nightingale’s Health News and The Washington Post for his accomplishments in defending healthcare fraud and abuse and regulatory compliance matters. He also serves on the Fraud and Abuse Advisory Board for publisher, BNA, Inc.
Judy Ringholz, RN, JD, CHC, is a Compliance Director in Sonnenschein’s Health Care Group. She has more than 30 years of experience in health care as a clinical nurse, nurse manager, administrator, risk manager, and compliance officer for healthcare organizations, a legal nurse consultant in malpractice defense litigation and a compliance enforcement attorney in the OIG . These experiences afford her the advantage of considering virtually every perspective when assessing the effectiveness of an organization’s compliance program and policies & procedures, as well as identifying and managing internal risks and detecting opportunities to strengthen compliance efforts.
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