HHS Inspector General Daniel Levinson yesterday announced an initiative to encourage self-disclosure as a means to work with the OIG to resolve possible liability for physician self-referral and anti-kickback violations. The initiative is designed to raise awareness of self-disclosure and better explain how it is used to resolve violations. “A provider's self-disclosure of conduct continues to be an important factor in determining whether a CCA is appropriate,” wrote Levinson in an open letter to healthcare providers. A CCA, or certification of compliance agreement, is a less-extensive version of a corporate integrity agreement.
