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Health Care Self-Disclosure Protocols

On the flipside, a self-disclosing party must acknowledge that the conduct is a potential violation and cannot simultaneously seek an advisory opinion from OIG as to whether an actual violation occurred. A disclosing party must conduct an internal investigation rapidly, report the findings to OIG or certify that the investigation will be completed within 90 days, and take any necessary corrective action. Finally, disclosure could trigger a criminal review because OIG refers potentially criminal conduct to the Department of Justice. OIG

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