Waltz Comments on Interview with Former HHS Inspector General

Partner Judith Waltz was quoted in a Compliance Cosmos article, “Former IG Dan Levinson: Government Is ‘Highly Concerned’ About Fraud and Abuse Charges,” about an interview with former HHS Inspector General Daniel Levinson, who stepped down May 31 after 15 years on the job.

Waltz said the Self-Disclosure Protocol (SDP) used to report potential or actual violations requires organizations to acknowledge and accept that the disclosed conduct involves fraud and generally pay a civil monetary penalty that’s larger than the calculated damages or overpayment. “So while the SDP is often the best alternative in a bad situation, it is not without downsides, including possibilities for risks outside of the SDP process (e.g., liability to other payers),” she said.