Recently, the Office of Inspector General (OIG) published newly-issued guidance on the HHS OIG Grant Self-Disclosure Program (“Program”), which creates a formal framework for recipients, sub-recipients, and applicants for federal grant money to disclose potential violations of federal criminal, civil, or administrative law that may impact federally-awarded grants. Similar to the OIG’s Provider Self-Disclosure Protocol, the program offers incentives for self-disclosures in the form of reduced penalties and sanctions. The Program will be particularly important for individuals and entities, such as research universities, that receive federally-funded grants, as the Program establishes a specific process for making certain mandatory disclosures already required by law as well as provides guidance and incentives for making voluntary disclosures.
OIG advisory opinion
OIG rescinds advisory opinion to charity
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For the first time, the OIG has rescinded an advisory opinion issued to a charity.
According to the OIG, the advisory opinion – issued in 2006 and modified in 2015 – was revoked because the charity “failed to comply with…