Counsel for providers navigating the HHS-OIG Self-Disclosure Protocol, settlement, and CIA obligations.
Request a Free Case ReviewThe HHS-OIG Self-Disclosure Protocol (SDP) and the parallel DOJ corporate disclosure framework can convert a multi-year prosecution into a multi-month settlement. The same protocols are catastrophic for organizations that disclose before scoping the conduct adequately.
The decision to self-disclose is binary, time-limited, and irreversible. The judgment of when, what, and how to disclose is the entire engagement.
Health Law Alliance counsels healthcare operators considering or executing self-disclosure across the SDP framework, including scoping, settlement negotiation, and the Corporate Integrity Agreement (CIA) and Independent Review Organization (IRO) obligations that follow most resolved disclosures, in lieu of OIG exclusion. Engage privileged counsel before any disclosure is contemplated.
A subpoena or civil investigative demand sets the government’s starting record. What is produced, what is withheld as privileged, and what is preserved shapes the theory investigators build.
Our bench includes a former federal prosecutor who served as Chief Compliance Officer of UnitedHealth Group, OptumRx’s parent company.
Within 24 hours: parse every deadline in the audit notice, place a litigation hold on the claims at issue, and preserve adjudication logs before the PBM rotates them out.
Claim-by-claim reconstruction: prescriber PA rationale, plan criteria at time of fill, BMI/A1C/comorbidity support, step-therapy chain, and compounding regulatory posture. Every flagged script gets its own defense memo.
We draft and file the written appeal, quantify the PBM's extrapolation errors, and negotiate directly with the auditor and network relations.
If the PBM refuses a reasonable resolution, we file in federal court and pair the suit with regulatory defense at DEA, FDA, and the state board - so a PBM dispute does not escalate into a license action.
Health Law Alliance handles the response and any parallel appeal, licensing matter or referral as one coordinated matter, so the strategy does not change hands as the matter moves between forums.
The bench includes a former Assistant U.S. Attorney nominated for the DOJ Director's Award, senior healthcare-company counsel, and attorney-providers with experience across healthcare audits and investigations.
Agency and company marks identify former professional experience of individual HLA team members. They do not imply affiliation, endorsement, or a client relationship.
Before you write a single page of your written response, have a privileged conversation with attorneys who have overseen 2,000+ audits - from both sides of the table. Free, confidential, no retainer.