Finding an excluded person on your payroll is not, by itself, a catastrophe — but how you respond in the first 30 days determines whether the outcome is a negotiated settlement or a multiplied Civil Money Penalty. The OIG’s Self-Disclosure Protocol (SDP), first published in 1998 and most recently revised in November 2021, offers a path to resolve potential violations on materially better terms than waiting for a False Claims Act demand or an OIG audit. This hub covers when SDP applies, how to run a credible internal investigation, and what a self-disclosure actually looks like in practice.
What this guide will cover
- When the SDP applies — and when it doesn’t (criminal conduct, government-identified matters)
- How to scope the internal investigation the OIG expects to see
- Calculating damages: claim-by-claim vs. statistical sampling
- Drafting the self-disclosure submission — the sections that matter
- Settlement multipliers: 1.5x for SDP vs. 3x for forced disclosure
- Timing: the 12-month rule and why it’s strict
- What happens after submission — OIG review, settlement negotiation, release
- Remediation plans that the OIG actually accepts
Read now
- The Definitive Guide to OIG Exclusions — Section 11 covers the self-disclosure framework.
- The Legal Guide to OIG Exclusions — Paul Weidenfeld on how enforcement and disclosure interact.
- CMP Report — settlement data showing SDP vs. non-SDP outcomes.
- OIG Self-Disclosure Protocol (official) — the OIG’s own page on SDP mechanics.
Talk to our team
If you’ve already found an excluded person on your payroll, your next call is to outside counsel. If you’re building the program that makes that discovery less likely — or that catches it faster when it happens — we can help with the screening side.