multi-disciplinary team that deals with compliance issues for GoodHealth

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) the provider seems to have imposed budgetary constraints that they knew or should have known would prevent facilities from providing adequate care;

(2) care that is not of acceptable quality is being provided;

(3) there are medical coding errors going five years back that will likely total millions of dollars;

(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 prepare a paper and presentation for the CEO.  The CEO will submit the paper to the Board of Directors.  Be creative.  How should this be approached?

Start with these articles on Corporate Responsibility and Healthcare:

• 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

Here are some suggestions for the team to consider.

• What sort of penalties can be imposed by the OIG to address (1) through (5) above?
• Have the Directors breached any legal duty?
• Should the organization self-report?