Question

1. Hospital’s General Counsel and Compliance Officer are considering a voluntary disclosure. Which mechanism should they choose?

Answer 1

This Federal Register notice sets forth the recently issued compliance program steerage forhospitals developed by the workplace of
Inspector General (OIG) in cooperation with, and with input from, several
provider teams and trade representatives. several suppliers and provider organizations have expressed an interest in higher protective their operations from fraud and abuse through the adoption of voluntary compliance programs. The first compliance steerage, addressing clinical laboratories, was ready by
the independent agency and revealed within the Federal Register on March three, 1997. We believe the development of this second program
guidance, for hospitals, can continue as a positive step towards promoting a
higher level of moral and lawful conduct throughout the health care industry.
FOR more data CONTACT:Stephen Davis, workplace of Counsel to the
Inspector General, (202) 619–0070. SUPPLEMENTARY INFORMATION: The
creation of compliance program guidances has become a significant initiative
of the independent agency in its efforts to interact the private health care community in combating fraud and abuse. In developing these compliance steerages, the independent agency has in agreement to figure closely with the Health Care finance Administration, the Department of
Justice and varied sectors of the health care trade. the primary of those compliance guidances centered on clinical laboratories, and was meant
to provide clear steerage to those segments of the health care trade that
were fascinated by reducing fraud and abuse among their organizations. The
compliance steerage was reprinted in an independent agency Federal Register notice published on March three, 1997 (62 Fr 9435). This second compliance program guidance developed by the independent agency continues to make upon the essential elements contained in our initial compliance guidance, and encompasses principles that square measure applicable to
hospitals similarly as a wider form of organizations that give health care
services to beneficiaries of health care, Medicaid and every one alternative Federal health care programs. Like the previously-issued
compliance program steerage for clinical laboratories and future compliance program guidances, adoption of the hospital compliance program steerage set forth below can be voluntary. Future compliancemprogram guidances to be developed can be equally structured and supported substantive policy recommendations, the elements of the Federal Sentencing Guidelines, and applicable statutes, regulations and Federal health care program needs.