Voluntary Disclosure Survey Results
The American Health Lawyers Association recently released the results of its Voluntary Disclosure Survey. The Survey provides data and observations regarding the experience of healthcare organizations with the government voluntary disclosure process. There were 195 respondents. Some of the important findings include:
- 71% of respondents had been involved in a voluntary disclosure to the government.
- 70% of the disclosures involved overpayment or billing/coding errors and 28% involved Kickback or Stark violations
- 70% of the disclosures were made by outside counsel.
- Most of the disclosures were made to OIG, followed by government contractors (e.g., fiscal intermediaries) and U.S. Attoney's Offices.
- Almost half (49%) of the disclosures were resolved within a year of the disclosure.
- 46% of the disclosures were resolved with a full overpayment refund; 12% resulted in a corporate integrity agreement.
The complete survey results are located here.
