DOJ Fraud Division and HHS-OIG coordinate self-disclosure of potentially criminal health-care fraud

What changed

• A company that voluntarily self-discloses health-care-program misconduct to DOJ's Fraud Division under the Corporate Enforcement Policy now also "shall receive the benefits of the HHS-OIG SDP". Only one disclosure is required; DOJ forwards it to OIG.
• OIG separately revised its protocol to state that "the SDP is not available for disclosure of Federal crimes". Criminal conduct disclosed to OIG is referred to DOJ.

What this establishes

One entry point for potentially criminal matters, connecting two existing credit frameworks.

What this does not establish

• No immunity, guaranteed declination or settlement entitlement. Corporate Enforcement Policy declination applies "absent aggravating circumstances" and requires cooperation and remediation.
• The SDP's benefits do not include resolution of mandatory exclusion under 42 U.S.C. §1320a-7(a).
• A disclosure made only to OIG generally does not qualify for Corporate Enforcement Policy declination.
• The policy creates no enforceable rights.

Sources

• DOJ OPA release: self-disclosure protocol Primary · 2026-10-15 · checked 2026-10-19
• DOJ policy document (coordination policy) Primary · 2026-10-15 · checked 2026-10-19
• HHS-OIG Self-Disclosure Protocol (revised) Primary · 2026-10-15 · checked 2026-10-19

Related on this site

• Policy §3
• Enforcement E03
• Records ledger

Register: the record store · record id doj-hhs-oig-health-care-self-disclosure-protocol-2026-10-15 · SOURCE-VERIFIED · HUMAN REVIEW PENDING.