You lead a multi-disciplinary team that deals with compliance issues for GoodHealth, Inc., a large healthcare provider that owns four hospitals. Your team did some investigating, including internal audits and confidential interviews, and they found the following:

(1) One of the facilities rents imagining equipment from staff radiologists and that equipment is located in the radiologists' private, off-campus office;

(2) medical staff have been offered bonuses for increasing admissions and referrals;

(3) there are medical coding errors going five years back that represent millions of dollars of overcharges;

(4) medical errors are not being consistently reported; and,

(5) physician peer review for medical errors is not taking place in a consistent or timely manner.

Your team has concluded that it is in the best interest of GoodHealth, Inc. to self-report to the OIG. The team must present to the CEO. The CEO will submit the paper to the Board of Directors. Be creative. How should this be approached?

Links

https://oig.hhs.gov/fraud/docs/complianceguidance/Corporate%20Responsibility%20and%20Health%20Care%20Quality%206-29-07.pdf

https://oig.hhs.gov/fraud/docs/complianceguidance/040203corpresprsceguide.pdf