The Health Law Section submitted comments to CMS' Provider Self-Disclosure Protocol

Health Law Section Submits Comments to CMS' Provider Self-Disclosure Protocol

The American Bar Association Health Law Section has filed comments in response to the solicitation by the Office of Inspector General of the Department of Health and Human Services of information and recommendations for revising the OIG’s Provider Self-Disclosure Protocol (the “SDP”), as published at 77 Fed. Reg. 36281 (June 18, 2012).

These comments were prepared by a membership task force of the Section (the “SDP Task Force”). Contributors to these comments from the SDP Task Force were Joseph V. Geraci, Amy K. Fehn, Gilbert F. Ganucheau and Donald H. Romano. In addition, William W. Horton, Co-Chair of the Section’s Health Law and Policy Coordination Committee, served as reviewer of the Task Force’s work and participated in the preparation of the final comments. The final comments were approved by the Section’s Council on August 14, 2012.

For more information about the ACO Task Force please contact Simeon Carson, Associate Director, at