OIG Newsroom · November 2, 2026 · Primary source
Updated FAQ: Health Care Fraud Self-Disclosure
Summary
OIG updated its Health Care Fraud Self-Disclosure Protocol (SDP) FAQ page to reflect a 2026 expansion of disclosure options, directing entities to distinct pathways depending on the nature of the conduct: criminal conduct to DOJ, OIG administrative-remedy matters to the OIG SDP, combined FCA and CMS administrative matters to a new FCA Self-Disclosure Pilot Program, and Stark Law-only matters to the CMS Voluntary Self-Referral Protocol. The FAQ also addresses how OIG calculates damages for claims submitted for services of unlicensed individuals, specifying that total employment or contracting costs serve as the proxy for damages and that OIG will not reduce that figure by federal payor mix. OIG confirms it coordinates closely with DOJ on all disclosures across programs.
What this may mean
Healthcare providers, suppliers, and others subject to OIG CMP authority, including pharmaceutical and device manufacturers, now face a differentiated self-disclosure landscape in which the choice of disclosure venue depends on whether FCA liability, OIG administrative liability, CMS administrative liability, or Stark Law exposure is implicated. For unlicensed-individual claims, OIG's damages calculation uses total employment costs as the proxy without a payor-mix reduction, creating a higher financial exposure than the excluded-individual framework. Entities under existing integrity agreements must contact their OIG monitor before submitting any self-disclosure.
Informational only. Not legal, medical, financial, or other professional advice. Always consult a qualified professional familiar with your specific facts before relying on any item.
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