When a company decides to self-disclose misconduct (or conduct that may be construed as such) to the government, that decision triggers a stream of additional questions. In the weighty deliberations about whether and what to disclose, entities often overlook another important decision: where to disclose. The decision whether to self-disclose misconduct through the OIG-HHS Provider Self Disclosure Protocol is not to be taken lightly. Indeed, many providers, entities, suppliers, etc. are unaware there is another option: voluntary self-disclosure to the Department of Justice. There are benefits and downsides to each self-disclosure avenue that should be considered when making this decision.
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