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TRICARE Operations Manual 6010.62-M, April 2021
Program Integrity
Chapter 13
Section 5
Administrative Remedies And Actions (Provider Exclusions, Terminations, Temporary Suspension Of Claim(s) Processing, Reinstatement, Conflict Of Interest, Reporting Refunds, Self-Disclosure) Payments
Revision:  C-6, May 30, 2024
1.0  SCOPE AND PURPOSE
1.1This section specifies which individuals and entities may, or in some cases must will, be excluded from the TRICARE program Program. It outlines the authority given to the Department of Health and Human Services/Office of Inspector General (DHHS/OIG) to impose exclusions from all Federal health care programs, including the TRICARE Program.
1.2  This section also outlines the Defense Health Agency (DHA) authority for exclusions and terminations.
1.3  In addition, this section states the effect of exclusion, factors considered in determining the length of exclusion, and provisions governing notices, determinations, and appeals.
1.4  This section also outlines procedures and protocol for suspension of claims processing, conflict of interest, Voluntary Self-Disclosure protocol, and provider self-reported refunds.
1.1  The Uniform Services Family Health Plan (USFHP) is exempt from this requirement.
1.2  The Accountable Care Organization (ACO) is partially exempt as follows:
1.2.1  All claims where care is provided and paid by the ACO are exempt from this requirement. These claims are reported to DHA using the Batch TRICARE Encounter Data (TED) Record(s) process.
1.2.2  All claims where the costs are shared by the ACO and Government or are paid entirely by the Government are subject to the requirements specified in this section. These claims are reported to DHA using the Voucher TED Record(s) process. All transactions related to these claims, to include reimbursement by the ACO, shall be held in temporary suspense, in accordance with the provisions outlined in this section.
1.3  Future Health Care Programs Funded Under A Capitation Agreement
All health care claims where the health care services provided are 100% covered under a capitation (https://manuals.health.mil/pages/DownloadManualFile.ashx?Filename=Definitions.pdf) agreement are exempt from this requirement. All health care claims not 100% covered under a capitation agreement (to include shared costs) are subject to the temporary suspension requirements outlined in this section.
2.0  DHA AUTHORITY FOR TEMPORARY SUSPENSION OF CLAIM(S) PROCESSING PAYMENTS
2.1  DHA may temporarily suspends claim(s) processing payments to specific provider, pharmacies, or client beneficiaries based upon fraud, abuse, or conflict of interest per 32 CFR 199.9(h) provisions. See https://manuals.health.mil/pages/DownloadManualFile.ashx?Filename=Definitions.pdf for the definition of “client beneficiary.”
2.2  The Director, DHA or designee may temporarily suspends claim(s) processing payments without prior notification to notifying the provider, pharmacy, entity, or client beneficiary of the intent to suspend payments to protect the public fisc. The Government will advise the provider, pharmacy, entity within 30 days of claims payment suspension that a temporary suspension has been ordered with a statement of the basis of the decision to suspend payment.
2.2.1  Within 30 calendar days of the claims suspension, DHA will provide written notice advising the beneficiary or provider that a temporary suspension has been ordered and a statement of the basis of the decision to suspend payment.
2.2.2  The suspension of claims processing will be for a temporary period pending the completion of investigation and any ensuing legal or administrative proceedings, unless sooner terminated by the Director, DHA or designee. See 32 CFR 199.9 for additional guidance.
2.2.3  DHA Program Integrity Office (PI) is responsible for advising the contractor of any suspension of claims processing.
2.2.4  The contractor shall then issue special notifications. (Addendum A, Figure 13.A-6, Figure 13.A-7, and Figure 13.A-8.)
2.3  The contractor shall send the temporary suspension of payment notification (Addendum A, Figure 13.A-6 or Figure 13.A-7 as appropriate) to the provider, pharmacy, entity or client beneficiary in lieu of sending an Explanation of Benefits (EOB) or other claims settlement notifications of a claim(s) payment suspension.
2.3.1  The contractor shall not send out claim(s) payment temporary suspension notifications above normal claim(s) settlement notifications.
2.3.2  The contractor shall not send out any document (EOB, etc.) to the client beneficiary stating the amount owed by the client beneficiary to the temporarily suspended provider during the suspension period.
2.4  The claims payment suspension is for a temporary period pending the completion of investigation, to include an ensuing any legal or administrative proceedings, unless sooner determined by the Director, DHA or designee. See 32 CFR 199.9(h) for additional guidance.
Note:  Both the Government and the contractor are sending out temporary suspension notifications. The contractor shall send out the standard temporary suspension notification (Addendum A, Figure 13.A-6 and Figure 13.A-7 as appropriate) in lieu of sending and EOB. The letters notify the provider or client beneficiary the claims was received but not paid at Government direction. The Government will send out the letter advising the provider why payments were suspended and how to proceed to remove the claim(s) from suspension.
2.5  Contractor Responsibilities
2.5.1  Upon notification from DHA to temporarily suspend claim(s) payments to specific providers, pharmacies, entities, or client beneficiaries, the contractor shall take the following six actions:
2.5.1.1  Cancel all pending non-underwritten and underwritten payments where funds have not been mailed or electronically transmitted, and the contractor can stop the release of funds in accordance with paragraph 2.5.2.
2.5.1.2  Follow Government direction in regard to underwritten debt. If instructed to convert debt from underwritten to non-underwritten, then submit and invoice in accordance with paragraph 2.5.3. This paragraph does not apply to the TRICARE Overseas Program (TOP), TRICARE Pharmacy (TPHARM) and TRICARE Medicare Eligible Program (TMEP) contracts.
2.5.1.3  Cease all current collection of non-underwritten debt related to the temporary suspended provider, pharmacy, entity, or client beneficiary, in accordance with paragraph 2.5.4.
2.5.1.4  Temporarily suspend the processing of updates to all non-underwritten and underwritten claims received and paid prior to receiving the notice of suspension in accordance with paragraph 2.5.5.
2.5.1.5  Process all new non-underwritten and underwritten claims received after the notification of temporary suspension in accordance with paragraph 2.5.6.
2.5.1.6  Forward all funds received after the notice of temporary suspension from or on behalf of the suspended providers, pharmacies, or entities to DHA, Contract Resource Management (CRM) in accordance with paragraph 2.5.7.
2.5.2  Attempt To Withhold Release of Payments Where Funds Have Not Been Mailed Or Electronically Transmitted At The Time Of Temporary Suspension Notice
Where reasonably possible, the contract shall try to prevent the release of Government payments to the suspended provider when notified of the provider’s suspension. This requirement does not apply to all payments pending release. The Government understands there is a stage in the disbursement process where, though the payments have not been mailed or transmitted, they have progressed to a point where they cannot be stopped without significant effort and cost.
2.5.2.1  The contractor shall determine the point, if any, where the release of payment for claims received prior to receiving the notice of temporary suspension can be stopped.
2.5.2.2  The contractor shall, for all payments intercepted prior to release and reported as paid to DHA on a TED Record(s), update (usually Cancel) previously reported TED Record(s) (contractor report of payment) to show no payment occurred.
2.5.2.3  The contractor shall not cancel or issue a stop payment order on any Electronic Funds Transfer (EFTs) or checks where the wire transfer has already been sent, where the check has been mailed, or where the payment was not intercepted.
2.5.2.4  The contractor shall, for any payment that is returned, or becomes stale-dated, or is on the refund file (in the process of being crediting back), process claims in accordance with paragraph 2.6.
2.5.2.5  The contractor shall process all collections received prior to the notice of suspension from or on behalf of any temporarily suspended provider, pharmacy, or entity in accordance with paragraph 2.6.
2.5.2.6  Pharmacy contractor only. The contractor shall process all pending reversals up to the date of temporary suspension notification. All reversals received on or after receipt of the notice of suspension shall be held by the contractor unless notified by DHA, Program Integrity (PI) to process the reversals.
2.5.3  Procedure For Converting Underwritten Debt To Non-Underwritten Debt (Excludes TOP, TPharm, and TMEP Contracts)
At the Government’s discretion, the Government will require the contractor to convert its underwritten debt to non-underwritten debt. The conversion of debt (underwritten to non-underwritten) shall not involve the temporarily suspended provider(s), pharmacy(s), or entity(s); the debt conversion is an administrative transaction between the contractor and the Government. If required to convert debt from underwritten to non-underwritten the contractor shall:
2.5.3.1  Submit an invoice billing the Government for the debt owed to the contractor by the temporarily suspended provider, pharmacy, or entity. The supporting document shall include the amount owed by TED Record(s) Indicator (TRICARE Systems Manual (TSM), Chapter 2, Section 2.9).
2.5.3.2  The Government will issue payment to the contractor and record an Accounts Receivable (A/R) entry into the accounting system under the temporarily suspended provider, pharmacy or entity name. The Government will not attempt collection during the suspension period.
2.5.3.3  At the Government’s discretion, debt converted to underwritten to non-underwritten will be returned to the contractor as non-underwritten debt in accordance with paragraph 2.9.5.
2.5.4  Procedure For Existing Debt At The Time Of Temporary Suspension
During the temporary suspension period and while the TED Record(s) Debt is in a ‘do-not process’ status the contractor shall:
2.5.4.1  Upon receipt of notification of temporary suspension, cease all non-underwritten debt collection efforts.
2.5.4.2  Not bill for Other Health Insurance (OHI), transfer debt to DHA or conduct any additional claims processing.
2.5.4.3  Not update any TED Record(s). Any DHA-directed action to collect debt or correct any claims processing errors, to include: Duplicate Claims System (DCS), OHI, Ineligibles, or beneficiary copay adjustments, Tax Levy, Payment offset, etc., (this is not an all-inclusive list) will be approved by DHA, PI prior to taking any action.
2.5.4.4  Forward all funds collected after receipt of the notice of temporary suspension from or on behalf of the suspended provider, pharmacy, or entity in accordance with paragraph 2.5.7.
2.5.4.5  Comply with all applicable reporting requirements related to A/R by separately reporting Temporarily Suspended Fiscal Intermediary (FI) Receivable debt for each suspended provider, pharmacy, or entity by the following two categories:
•  FI Receivable debt by temporarily suspended providers in a ‘do-not process’ (do-not-pursue collection) status.
•  FI Receivable debt related to temporarily suspended providers in a ‘process’ (actively pursuing collection) status (see paragraph 2.7).
Continue to age and include temporarily suspended debt on the monthly FI Receivable report.
Note:  Temporarily Suspended FI Receivable debt shall only relate to TED Record(s) data submitted on Vouchers. The TED Record(s) data submitted on Batches was not paid and therefore there is no associated debt. Details for reporting suspended A/R for temporarily suspended providers are identified in DD Form 1423, Contract Data Requirements List (CDRL), located in Section J of the applicable contract.
2.5.4.6  Regional contractors only: If underwritten debt existed prior to the notice of temporary suspension and the Government did not convert the debt to non-underwritten in accordance with paragraph 2.5.3, the contractor may continue to pursue its underwritten debt collection efforts against the suspended provider, pharmacy, entity, or client beneficiary. All unsolicited/voluntary refunds (underwritten and non-underwritten) shall be processed in accordance with paragraph 2.5.7.
2.5.4.7  Claims Processing and Payment Exceptions for paragraph 2.5.4
Contractor shall not bill for OHI, transfer debt to DHA or conduct any additional claims processing unless:
2.5.4.7.1  Authorized by DHA, PI:
2.5.4.7.2  Authorized under paragraph 2.6; or
2.5.4.7.3  Authorized under paragraph 2.7; or
2.5.4.7.4  Authorized under paragraph 2.8.
2.5.5  Procedure For Processing Updates To Claims Received Prior To Temporary Suspension Notice
2.5.5.1  All proceeds received prior to the temporary suspension notice are applied to the suspended provider’s TED Record(s) Debt in accordance with paragraph 2.6.
2.5.5.2  All proceeds received after the notice of temporary suspension are forwarded by EFT, check, or special endorsement to DHA, CRM in accordance with paragraph 2.5.7.
2.5.5.3  All updates (positive or negative), received after the notice of temporary suspension, to previously paid claims (claims received and paid prior to the notice of suspension) are held in suspense by the contractor. No TED Record(s) updates (Batch or Voucher) are done.
Note:  TED Record updates received prior to the notice of temporary suspension pending submission to DHA shall be processed to completion and sent to DHA after receiving the notice of suspension. The contractor shall stop updates resulting in payments if possible.
2.5.6  Procedure For Processing New Claims Received After Temporary Suspension Notice
The contractor shall process all new claim submissions received after notice of temporary suspension of a provider, pharmacy, entity, or client beneficiary as an initial Batch TED Record then immediately place TED Record(s) in a ‘do-not process’ status suspending the claim from further processing. The contractor shall not make payments to the provider, pharmacy, entity, or client beneficiary nor apply calculated payment amounts to the provider’s, pharmacy’s, or entity’s TED Record(s) debt for any claim processed as a Batch. To submit claims using the Batch process the contractor shall:
2.5.6.1  Cite Header Type Indicator 0 (Batch Header no claim rate) OR 9 (Batch Header claim rate eligible) as appropriate (TSM Date Element 0-001);
2.5.6.2  Cite Contract Line Item Number/ Automated Standard Application for Payment (CLIN/ASAP) Account Number 00000000 (TSM Data Element 0-025);
2.5.6.3  Cite Adjustment Key 0 (TSM Data Element 1-035- or 2-035); and
2.5.6.4  Cite Override Code NP - Payment to provider, pharmacy, entity, or client beneficiary temporarily suspended at the direction of DHA, PI (TSM Data Elements 1-160 and 2-095).
2.5.6.4.1  Override Code NP is only used for new claims received after the notice of temporary, processed as a Batch (informational TED Record(s)), and payment is being held in accordance with the notice of suspension.
2.5.6.4.2  Updates to claims paid prior to receiving the notice of temporary suspension are held in suspense (i.e., no TED Record(s) updates) in accordance with paragraph 2.5.5. Shall not cite Override Code = NP when submitting Vouchers.
2.5.7  Procedure For Processing Debt Payments And Unsolicited/Voluntary Refunds Received Temporary After Suspension Notice
All funds received from or on behalf of the temporarily suspended provider(s), pharmacy(s), entity(s) for claims subject to the suspension are forwarded (by EFT, check or special endorsement) to DHA, CRM and are not applied as payment to the suspended provider’s, pharmacy’s, or entity’s TED Record(s) Debt. All unsolicited/voluntary refunds (underwritten and non-underwritten) are forwarded to DHA, CRM. The funds are placed into a ‘Deposit Fund’ in accordance with the Department of Defense (DoD) Financial Management Regulation (DoD 7000.14-R, Volume 12, Chapter 1, Paragraph 0108 & 010803) “Monies held by the U.S. Government awaiting distribution on the basis of a legal determination or investigation.” For all funds received after the notice of suspension from or on behalf of the suspended provider, pharmacy, or entity, the contractor shall:
2.5.7.1  Forward checks payable to the contractor to DHA, CRM with the following Special Endorsement: “Pay to the order of US Treasury, ALC 97000012”. The contractor shall endorse the checks. If the remittance is deposited by the contractor, the contractor shall remit the funds to DHA, CRM by check or EFT payable to the US Treasury, ALC 97000012. Funds collected in accordance with paragraph 2.6 are accepted.
2.5.7.2  Not deposit proceeds received after the notice of temporary suspension in its non-underwritten bank account.
2.5.7.3  Not create TED Record(s) updates for any funds transferred to DHA, CRM to be placed in a ‘Deposit Fund’ on behalf of the temporarily suspended provider, pharmacy, or entity pending the outcome of the suspension investigation.
2.5.7.4  Advise the payer using special notification the funds received have been placed in a Government owned ‘Deposit Fund’ (Addendum A, Figure 13.A-9).
2.6  TED Record(s) Processing Exceptions Processing For Claims
The following TED Record(s) updates shall not require approval from DHA, PI and TED Record(s) updates are processed in accordance with the TSM.
2.6.1  The contractor shall supply all collections received prior to the notice of temporary suspension to the provider’s, pharmacy’s, or entity’s TED Record(s) debt with corresponding TED Record(s) updates.
2.6.2  The contractor shall, for any payment that is returned, becomes stale-dated, intercepted in accordance with paragraph 2.5.2, or is on a refund file (in the process of crediting back) process claims as follows:
2.6.2.1  NOT reissue payment (even if a request is received from the payee).
2.6.2.2  Submit the corresponding credit TED Record(s) reporting non-payment of claim in accordance with Chapter 3, Section 4.
2.6.2.3  Deposit the returned funds in the CLIN/ASAP Account originally used to make payment (if applicable). If the CLIN/ASAP Account originally used for payment is closed the contractor shall deposit funds into the current Fiscal Year (FY) CLIN/ASAP Account assigned for the same purpose.
2.6.2.4  Process TED Record(s) adjustments (Vouchers) to temporarily suspended providers as necessary to ensure the reported TED Record(s) payments (Amount Paid Government Contractor, TSM, Chapter 2, Section 2.4, Record Locator 1-140 or 2-205 equal actual amounts executed under the contract (payments excluding offsets). If the contractor is not sure a TED Record(s) update is needed or authorized for non-underwritten bank reconciliation or underwritten cost reimbursement purposes during the suspension period, contact DHA, CRM for reconciliation.
2.6.2.5  Process all TED Record(s) updates as required under Section H.10. ANNUAL UNDERWRITTEN UNALLOWABLE HEALTHCARE COST COMPLIANCE REVIEW Cost of Care audit requirements. This requirement applies to TED Record(s) data submitted under a Voucher header. TED Record(s) data submitted under a Batch header is excluded from audit as the Batch TED Records are informational records and no expenditure of Government funds occurred based upon the TED Record(s) (TSM, Chapter 2, Section 2.3).
2.7  Procedure For Partial Release Of Payments During Temporary Suspension
During the temporary suspension period (pending the completion of investigation, to include any ensuing legal or administrative proceedings) the Government will, at its discretion, instruct the contractor to move suspended provider, pharmacy, entity, and client beneficiary TED Record(s) from a ‘do-not process’ status to a ‘process’ status while retaining the suspension on all remaining and future claims received. The Government will removed claims from a ‘do-not-process’ status to ‘process’ status based upon date of receipt are embedded in the Internal Control Number (ICN) (TSM, Chapter 13, Section 5). Claims will be released using a date range on an oldest to newest basis. This action will release some or all TED Record(s) process to-date under suspense for a specific provider, pharmacy, entity or client beneficiary; however it does not change the providers’, pharmacies’, or entities’ suspension status. The suspension remains in effect for all claims not covered by the ‘process’ release and for all new claims received.
2.7.1  For all temporarily suspended provider claims set to a ‘process’ status the contractor shall:
2.7.1.1  Process the claims-to-date as a Voucher citing Special Processing Code (SPC) NQ - ‘PI Temporarily Suspended Provider, Pharmacy, Entity, or Client Beneficiary claim in ‘PROCESS STATUS.’ Claim updates shall include but are not limited to: DCS, OHI, Ineligibles, beneficiary copay adjustments, Cost of Care audit findings, Tax Levy, Payment offset, etc., occurring after the suspension date. All TED Records set to a ‘process’ status while the provider, pharmacy, entity, remains suspended are submitted as non-underwritten vouchers cite SPC NQ and remain non-underwritten for the life of the claim. SPC NQ is listed for all claims submitted and adjusted as a Voucher and paid as non-underwritten during the temporary suspension release(s). SPC NQ allows DHA to identify all claims actually paid and collected during the temporary suspension waiver.
2.7.1.2  Cancel corresponding Batch TED Record(s) citing Override Code NP - ‘Payment to the Provider, Pharmacy, Client Beneficiary or Entity Temporarily Suspended at the Direction of DHA PI. Do not cite Override Code = NP when submitting Vouchers.
Note:  All TED Records set to a ‘process’ are submitted to DHA as non-underwritten Vouchers for the life of the claim.
2.7.2  For all debt associated with TED Records in a ‘process’ status, the contractor shall follow the recoupment process as described in Chapter 10, Section 4. All funds recovered for TED Records set to a ‘process’ status are applied to the provider’s, pharmacy’s, entity’s TED Record(s) debit and are deposited by the contractor into the CLIN/ASAP Account originally used for payment. If the CLIN/ASAP Account originally used for payment is closed the contractor shall deposit the funds into the current FY CLIN/ASAP Account assigned for the same purpose. The date Government notification was received to set the TED Record(s) to ‘process’ and fund under the ‘process’ order (if any) held by DHA/CRM in a ‘Deposit Fund’ were returned to the contractor is the start date to initiate debt collection activities. The date of demand in accordance with 45 CFR 30.11 is used as the new debt aging date and is the new aged-based date for potential transfer to DHA if the claim(s) return uncollectable.
2.7.3  All amounts owed to the provider, pharmacy, or entity for TED Records set to a ‘process’ status are first applied to the provider’s, pharmacy’s, or entity’s active debt (debt related to TED Records set to a ‘process’ status) and any remaining amounts owed are paid to the provider, pharmacy, entity or client beneficiary.
2.7.4  The contractor shall deposit any funds applied to the provider’s, pharmacy’s, or entity’s debt into its current FY non-underwritten bank account and submit a TED Record ‘cancellation’ showing the reduction in amount paid to the provider, pharmacy, or entity. If the contractor is unable to submit a TED Record Cancellation or Adjustment, the contractor shall report the deposit(s) on the monthly Bank Reconciliation Report in accordance with paragraph 2.9.5.5.
2.8  Procedure For Full Release Of Temporary Suspension
Upon notification of DHA PI that the provider, pharmacy, or entity is no longer under suspension the contractor shall:
2.8.1  For all claims received after notification by DHA PI the temporary suspension has ended, receive specific guidance from DHA as to how to proceed.
2.8.2  If instructed by DHA, PI to process temporarily suspended TED Record(s) data, coordinate with DHA, CRM regarding the disposition of all pending adjustments and cancellations to TED Record(s) paid prior to the notice of suspension (in accordance with paragraph 2.5.5) that remain in a “do-not process’ status at the time of suspension release. This coordination ensures the TED Record-based transactions submitted by the contractor are recorded and paid correctly by the DHA financial systems.
2.8.3  Receive specific instruction from DHA, CRM regarding the disposition of all funds held in ‘Deposit Fund’.
2.8.4  The contractor shall reset the debt aging date to the date of temporary suspension release when directed by DHA. The date Government notification was received to release suspension of claims and the date funds (if any) held by DHA, CRM in a ‘Deposit Fund’ were returned to the contractor is used as the start date to initiated debt collection activities. The date of demand in accordance with 42 CFR § 30.11 is used as the new debt aging date.
2.9  Other Instructions To The Contractor
2.9.1  On contracts where the TED Record(s)-based administrative (also known as claim rate) payments are authorized, the contractor is authorized one administrative payment for each new TED Record required by Government direction (e.g., claims processed as a Batch and then changed to a ‘process’ status or released from temporary suspension shall receive one administrative payment for creating the original Batch TED Record and a second administrative payment for creating the new Voucher TED Record).
2.9.2  All claims being held based upon the notice of temporary suspension are excluded from Section H audit requirements except, in accordance with paragraph 2.6.2.5, the Section H.10 ANNUAL UNDERWRITEN UNALLOWABLE HEALTHCARE COST COMPLIANCE REVIEW Cost of Care audit requirements.
2.9.3  The contractor shall not apply the identified patient responsibility (applicable cost-shares, copayments, deductibles) towards the catastrophic cap for claims that are not fully processed. The contractor shall apply the identified patient responsibility on claims fully processed prior to the temporary suspension notice (and not intercepted, paragraph 2.5.2) or fully processed in accordance with paragraphs 2.6, 2.7, or 2.8.
2.9.4  At the end of the contract and for all providers, pharmacies, entities, or client beneficiaries that remain in temporary suspense, the contract shall transfer all Batch and Voucher TED Record(s) data to the new contractor in accordance with Chapter 2, Section 8. All additional materials being held in suspense related to the suspended Batch and Voucher TED Record(s) data is transferred to the new contractor’s Program Integrity (or equivalent) office in accordance Chapter 2, Section 10, paragraph 1.0.
2.9.5  Debt Transferred To DHA And Returned To The Contractor
When a provider, pharmacy, or entity is under a temporary suspense order, all non-underwritten debt collection efforts shall cease, to include collection efforts related to debt previously transferred to DHA that remains uncollected. Upon release of suspension or partial release of suspension (Process Status), any debt falling with in the suspension release period and transferred to DHA will be transferred back to the contractor and the collection process shall start over. The contractor shall:
2.9.5.1  Reestablish the debt on its A/R system within 30 days after receiving funds placed in ‘Deposit Fund’ and debt information from the DHA, Office of General Counsel (OGC). Regional Contractors: All debt returned to the contractor is non-underwritten debt.
2.9.5.2  Issue a demand letter within 30 days after the debt has been reestablished using the date of demand as the new debt aging date in accordance with 45 CFR § 30.11.
2.9.5.3  All interest and penalty timelines shall start over within the date of demand as the aging start date of debt.
2.9.5.4  If the debt remains uncollectable it is transferred back to DHA, OGC in accordance with Chapter 10, Section 4 using the date of demand after the debt was transferred back as the aging start date.
2.9.5.5  Regional Contractors Only
Deposit all collections of converted debt into the current FY non-underwritten bank account assigned to them. Because TED Record(s) credit data submissions shall have already been sent to DHA for all under written debt converted to non-underwritten debt, the monthly deposits of converted debt will create an out-of-balance on the bank reconciliation report. The contractor shall separately report on its monthly bank reconciliation report (in summary) all collections for converted debt. Details for reporting are identified in DD Form 1423, CDRL, located in Section J of the applicable contract.
3.0  DHA AUTHORITY FOR EXCLUSIONS AND TERMINATIONS
3.1  DHA may exclude exclusion of any individual or entity is based on 32 CFR 199.9(h) provisions.
3.2  The contractor shall provide written notice to DHA PI within 10 calendar days of any situation involving a TRICARE provider, pharmacy, or entity whose actions warrant exclusion under DHA authority related to fraudulent or abusive behavior.
3.3  The Director, DHA or designee, has the authority to exclude an authorized TRICARE provider, pharmacy, or entity. The period of exclusion is at the discretion of DHA. (See 32 CFR 199.9.)
3.4  DHA PI is responsible for coordinating will coordinate and issuing issue notification of exclusion action. DHA PI will send written notice to the provider of the proposed exclusion, and the potential effect thereof. The individual or entity may submit evidence and written argument regarding the proposed exclusion.
3.5  DHA PI has sole authority to issue an Initial Determination of Exclusion. Written notice of this decision will include the basis for the exclusion, the length of the exclusion, as well as the effect of the exclusion. The determination also outlines the earliest date on which DHA PI will consider a request for reinstatement, the requirements for reinstatement, and appeal rights available.
3.5.1  DHA PI will notify appropriate agencies, including contractors, of all DHA exclusion actions taken.
3.5.2  DHA PI will be responsible for initiating initiate action based upon reversed or vacated decisions. Exclusion of a provider, pharmacy, or entity will be effective 15 calendar days from the date of the initial determination.
3.5.3  The Director, DHA or designee has sole authority for approval of any request for reinstatement.
4.0  CONTRACTOR ACTIONS UNDER TRICARE EXCLUSION AUTHORITY - 32 CFR 199.9
4.1  The contractor shall provide supporting documentation to DHA PI within 10 calendar days when recommending any provider exclusion.
4.2  DHA PI will notify the contractor of an exclusion action.
4.3  The contractor shall:
4.3.1  Ensure that no payment is made to an excluded provider, pharmacy, or entity for care provided on or after the date of the DHA action (15 calendar days from the date of the Initial Determination as noted in paragraph 3.5). Neither the provider, pharmacy, entity, nor the patient will be client beneficiary is entitled to TRICARE cost-sharing once the exclusion is in effect.
4.3.2  Notify DHA PI if a provider, pharmacy, or entity attempts to bill the program after the effective date of exclusion.
4.3.3  Ensure that an excluded provider, pharmacy, or entity is not included in the network and provider directory.
4.3.3.1  The contractor shall ensure that the network provider, pharmacy, or entity whose contract has been canceled clearly understands his or her status if cancellation of a network provider, pharmacy, or entity agreement is required.
4.3.3.2  Provide written notice within 15 business days, sent by certified mail, return receipt requested, that the network provider’s or network pharmacy’s agreement has been canceled.
4.3.3.3  Provide DHA PI a copy within 15 business days.
4.3.4  Notify, in writing within 10 calendar days, the beneficiary who submitted a claim that the provider has been excluded from the TRICARE program.
4.3.5  Ensure the enforcement of all exclusion action taken, and notify appropriate parties of the application of exclusions. For example, any claim received from an excluded third party billing agent shall be returned to the provider with instructions to resubmit the claim directly or through another third party billing agent. The provider remains entitled to reimbursement for covered services as long as they remain an authorized TRICARE provider.
5.0  DHHS/OIG APPLICATION OF SANCTION AUTHORITY
5.1  DHHS/OIG can excludes individuals or entities from participation in any federal Federal health care program to include the Department of Defense (DoD) Military Health System (MHS), and TRICARE. Authority and exclusion categories can be found are on the DHHS/OIG website.
5.2  DHHS/OIG has sole responsibility for issuing a written notice of its intent to exclude a provider, pharmacy, or entity, the basis for the exclusion, the effective date, the period of exclusion, and the potential effect of exclusion.
5.3  DHHS/OIG has sole authority for terminating an exclusion imposed under their its authority. DHHS/OIG will handle notifications of approval or denial of a request for reinstatement and are responsible for reversing or vacating decisions.
5.4  DHHS/OIG exclusions and reinstatements are issued on a monthly basis. DHHS/OIG will provide DHA PI with immediate access to this information, which will be forwarded to each contractor.
5.5  Exclusions taken by DHHS/OIG are binding on Medicare, Medicaid, and all Federal health care programs with the exception of the Federal Employee Health Benefit Program (FEHBP) (42 USC 1320a-7b(f)). No payment will be is made for any item or service furnished on or after the effective date of exclusion until an individual or entity is reinstated by DHHS/OIG, and subsequently meets the requirements under 32 CFR 199.6.
6.0  CONTRACTOR ACTIONS UNDER DHHS/OIG EXCLUSION AUTHORITY
6.1  DHA PI will provide the contractor the monthly issuance of DHHS/OIG exclusion and reinstatement actions.
6.2  The contractor shall ensure that no payment is made to an excluded provider, network pharmacy, or entity for care provided on or after the date of the DHHS/OIG action. The provider, pharmacy, or entity, nor the patient will not be client beneficiary entitled to TRICARE cost-sharing once the exclusion is effective.
6.2.1  The contractor shall notify DHA PI should when a provider, network pharmacy, or entity attempt to bill the program or if payment has been issued after the effective date of exclusion.
6.2.2  It is not necessary for the contractor to issue a separate letter notifying the provider, network pharmacy, or entity of the exclusion action.
6.3  The contractor shall ensure that an excluded provider, pharmacy, or entity is not included in the network.
6.3.1  The contractor shall ensure that the network provider or network pharmacy whose contract has been canceled understands his or her their status, if the cancellation of a network, or if applicable, participating provider agreement is required.
6.3.2  The contractor shall accomplish this by providing written notice, within seven calendar days, sent by certified mail, return receipt requested, that stating the network provider’s or network pharmacy’s agreement has been canceled. The contractor shall send a copy to DHA PI.
6.3.3  The contractor shall send a copy to DHA PI within seven calendar days.
7.0  CONTRACTOR APPLICATION OF SANCTION AUTHORITY
7.1  The contractor shall ensure the enforcement of all sanction action(s) taken, and notify appropriate parties of the application of sanctions. For example, any claim received from an excluded third party billing agent shall be is returned to the provider with instructions to resubmit the claim directly or through another third party billing agent.
7.2  The provider remains entitled to reimbursement for covered services as long as they remain an authorized TRICARE provider.
8.0  PROVIDER, NETWORK PHARMACY, OR ENTITY TERMINATION OF AUTHORIZED PROVIDER STATUS
8.1  The contractor shall terminate the authorized provider status of any provider, network pharmacy, or entity determined not to meet program requirements. The request for reinstatement will shall be processed under the procedures established for initial requests for authorized provider or network pharmacy status. See paragraph 10.0 for further information.
8.2  Other Listings
OtherThe contractor shall ensure receipt of the appropriate state board listings of actions affecting provider authorization status (e.g.i.e., Federation of State Medical Boards of the United States (US)) will be sent to each contractor. A provider who has licenses to practice in two or more jurisdictions and has one or more licenses suspended or revoked shall be terminated as a TRICARE provider in all jurisdictions.
9.0  CONTRACTOR REQUIREMENTS FOR TERMINATION
9.1  The contractor shall initiate termination action based upon a finding that the provider, pharmacy, or entity does not meet the qualifications to be an authorized provider when status as an authorized provider, authorized network pharmacy or authorized entity is ended.
9.2  Separate termination action by the contractor is not required for a provider, pharmacy, or entity sanctioned under the exclusion authority granted DHHS/OIG.
9.3  The period of termination will be indefinite and will end only after the provider, pharmacy, or entity has successfully met the established qualifications for authorized status under the TRICARE Program and has been reinstated as outlined in paragraph 10.0.
9.4  The contractor shall notify the provider, pharmacy, or entity in writing of the proposed action to terminate them.
9.4.1  The contractor shall specifically Government will direct the contractor to notify the provider, pharmacy, or entity of the proposed action to terminate their status as an authorized TRICARE provider when the provider, pharmacy, or entity falls within the contractor’s certifying responsibility and the provider, pharmacy, or entity fails to meet the requirements of 32 CFR 199.6 (Addendum A, Figure 13.A-9Addendum A, Figure 13.A-8).
9.4.1.1  The contractor shall not terminate the provider, pharmacy, or entity when he or she fails to return certification packets but flag the provider as ‘inactive’.
9.4.1.2  The contractor is not required to send a copy of the notice to DHA PI.
9.4.1.3  The contractor shall send the notice to the provider’s, pharmacy’s or entity’s last known business or office address.
9.4.2  The pharmacy contractor shall notify the pharmacy in writing of the proposed action to terminate the pharmacy status as a network pharmacy when it is not in compliance with its agreement and the pharmacy fails to meet the requirements of 32 CFR 199.6 (Addendum A, Figure 13.A-9).
9.4.3  The notice shall state that the provider, pharmacy, or entity will be terminated as of the effective date of the termination notice.
9.4.4  The notice shall also inform the provider, pharmacy, or entity of the situation(s) or action(s) which form the basis for the proposed termination.
9.4.5  For network providers, the notice shall inform the provider that his or her patients will be referred to another provider pending final action.
9.4.6  For a network pharmacy, the notice shall inform the pharmacy that beneficiary prescriptions may not be filled and any claims submitted will be denied.
9.4.2  The notice shall will offer the provider, pharmacy, or entity an opportunity to respond within 30 calendar days from the date of the notice. An extension to 60 calendar days may be granted if a written request is received during the 30 calendar days showing good cause.
9.4.3  The provider, pharmacy, or entity may respond with either documentary evidence and written argument contesting the proposed action or a written request to present in person evidence or argument to a contractor’s designee at the contractor’s location DHA, PI. Expenses incurred by the provider, pharmacy, or entity are their responsibility.
9.4.4  Once the notice of proposed action to terminate is sent, the provider’s claims will be are temporarily suspended from claims processing until an Initial Determination is issued. The provider, pharmacy, or entity will be is notified via the proposed notice that the claims will be are suspended from claims processing. However, beneficiaries will not be notified of the suspension.
9.4.5  For pharmacy claims, once the notice of proposed action to terminate is sent, the pharmacy’s claims will are not be processed as network claims until an Initial Determination is issued.
9.4.5.1  The pharmacy will be is notified via the notice that the claims will not be processed as network claims.
9.4.5.2  Beneficiaries will be are advised by the pharmacy that it is no longer a network pharmacy and that any prescription filled there will requires submittal of a claim for reimbursement by the beneficiary.
9.5  Initial Determination
9.5.1  The contractor shall Government will invoke an administrative remedy of termination if after the provider, pharmacy, or entity has exhausted, or failed to comply with the procedures for appealing the proposed termination and the decision to terminate remains unchanged by directing the contractor to issue a written notice of the Initial Determination via certified mail.
9.5.2  The contractor shall accomplish this by issuing a written notice of the Initial Determination via certified mail to the effective entity.
9.5.3  The contractor shall send a copy of the Initial Determination to DHA PI along with supporting documentation within seven calendar days.
9.5.2  The contractor shall include the following in the Initial Determination written notice:
9.5.2.1  A Unique Identification Number (UIN) indicating the fiscal year FY of the Initial Determination, a consecutive number within that fiscal year FY and the contractor’s name. A sample letter is found at Addendum A, Figure 13.A-10 Addendum A, Figure 13.A-9.
9.5.2.2  A statement of the action being invoked and the effective date of the action. The effective date shall will be the date the provider, pharmacy, or entity no longer meets the regulatory requirements. If there is no documentation the provider ever met the requirements, the effective date will be either June 10, 1977 (the effective date of the Regulation) or the date on which the provider, pharmacy or entity was first approved, whichever date is later. In the case of a pharmacy, it would be is the date on which the pharmacy first became part of the network.
9.5.2.3  A statement of the facts, circumstances, or actions that form the basis for the termination and a discussion of any information submitted by the provider, pharmacy, or entity relevant to the termination.
9.5.2.4  A statement of the provider’s, pharmacies, or entity’s right to appeal.
9.5.2.5  The requirements and procedures for reinstatement.
9.6  Providers Failing To Return Recertification Documentation
9.6.1  The contractor shall not terminateUpon notification from the Government the providers, pharmacy pharmacies, or entity failing entities who failed to return recertification documentation, the contractor shall terminate but shall be placed the providers, pharmacies, and entities on the inactive provider listing.
9.6.2  The contractor shall first verify that the recertification package was mailed to the correct address and was not returned by the US Postal Service (USPS).
9.6.3  The contractor shall ensure that no claims are paid and shall deny claims for services regardless of who submits the claim.
9.6.4  The contractor shall advise Government will notify the provider, pharmacy, or entity shall be advised that such action will be taken within 15 calendar days their TRICARE claims will be denied for failing to return their recertification documentation.
9.7  Requirement To Recoup Erroneous Payments
9.7.1  The contractor shall, after the Initial Determination letter has been issued, initiate recoupment in accordance with Chapter 10, Section 2 for any claims cost-shared, paid for services, or supplies furnished by the provider (including pharmacies) on or after the effective date of termination, even when the effective date is retroactive, unless a specified exception is provided by 32 CFR 199. This also applies to claims processed by previous contractor(s).
9.7.2  The contractor shall transfer all monies recouped, including those paid by previous contractor(s), to DHA Contract Resource Management (CRM) in accordance with Chapter 3.
9.8  File Requirements For A Terminated Provider, Pharmacy, Or Entity
The contractor shall include the following in the Initial Determination file for the provider, pharmacy, or entity:
9.8.1  Initial Determination of Termination Action as well as Proposed Notice to Terminate.;
9.8.2  Provider/pharmacy/entity certification file (i.e., the documentation upon which the original certification of the provider/pharmacy/entity was based) or network pharmacy agreement.;
9.8.3  All correspondence and documentation relating to the termination. (copies Copies of the enclosures must be are attached to the copy of the original correspondence).;
9.8.4  Documentation that the contractor considered or relied upon for in issuing the determination.
9.9  Special Action or Notice Requirements When An Institution Is Terminated
9.9.1  The contractor shall take appropriate action when a DHA determination is made that an institutional provider does not meet qualifications or standards to be an authorized TRICARE provider.
9.9.2  Provider And Client Beneficiary Notification
9.9.3  The contractor shall Government will:
9.9.3.1  Instruct the institution by certified mail to immediately give written notice of the termination to any TRICARE client beneficiary (or his or her beneficiary’s parent, guardian, or other representative) admitted to or receiving care at the institution on or after the effective date of the termination.
9.9.3.2  Notify any client beneficiary (or their beneficiary’s parent, guardian, or other representative) admitted prior to the date of the termination by certified mail that TRICARE cost-sharing ended as of the termination date when the termination effective date is after the date of the initial determination.
9.9.3.3  Advise the client beneficiary (or their beneficiary’s parent, guardian, or other representative) of their the client beneficiary’s financial liability.
9.9.3.4  Use a fast, effective means of notice (e.g., phone, fax, express mail, or regular mail, depending on the circumstances).
9.9.3.5  Notify any client beneficiary (or his or her beneficiary’s parent, guardian, or other representative) admitted prior to the grace period of the violation that TRICARE cost-sharing of covered care will continues during that period. Cost-sharing is to continues through the last day of the month following the month in which the institution is terminated if an institution is granted a grace period to effect correction of a minor violation.
9.9.3.6  Notify any client beneficiary (or their beneficiary’s parent, guardian, or other representative) admitted prior to a grace period of the institution’s corrective action, when such has been determined to have occurred, and the continuation of the institution as an authorized TRICARE provider.
9.9.4  Cost-Sharing Actions
9.9.5  The contractor shall deny cost-sharing for any:
9.9.5.1  New patient admitted after the effective date of the termination.;
9.9.5.2  Beneficiary admitted during a grace period granted an institution involved in a minor violation.;
9.9.5.3  Beneficiary already in an institution involved in a major violation beginning with the effective date of the termination.;
9.9.5.4  The contractor shall cost-share covered care for those beneficiaries admitted prior to a grace period.
10.0  PROVIDER REINSTATEMENTS
10.1  Reinstatement of an excluded individual or entity is not automatic once the specified period of exclusion ends.
10.2  The individual or entity must will apply for reinstatement and receive written notice from DHA that reinstatement has been granted.
10.3  32 CFR 199.9 provides that the Director, DHA or a designee, will have the authority to reinstate providers, pharmacies, or entities previously excluded or terminated under TRICARE. For providers sanctioned by Department of Health and Human Services (DHHS), see paragraph 3.0.
10.4  DHHS/OIG provides monthly updates for reinstated providers, individuals, pharmacies, and entities. The information includes exclusion date and reinstatement date when a previously excluded provider, pharmacy, or entity is reinstated by DHHS/OIG.
10.5  The contractor shall, before initiating reinstatement action:
10.5.1  Determine if any erroneous payments have been made to provider, pharmacy or entity during period of sanction.
10.5.1.1  The contractor shall certify the provider, pharmacy or entity as an authorized provider, and determine the effective date of the reinstatement if no funds have been paid for services to the provider while excluded or are otherwise owed the Government for claims paid prior to the exclusion.
10.5.1.2  If erroneous payments have been made to a provider, pharmacy, or entity during the period of exclusion, restitution of the payments shall be made before a request for reinstatement will be considered.
10.5.1.3  The contractor shall determine, if any payments have been made, and initiate restitution of the payments.
10.5.2  The contractor shall send the certification package to the provider, entity, or pharmacy for completion to ensure that the provider meets the requirements to be an authorized TRICARE provider under 32 CFR 199.6.
10.5.3  Verify that pharmacies has all required state licenses to operate as a pharmacy.
10.5.4  Ensure the exclusion or suspension shall remain in effect until the provider completes and returns the certification package and the determination is made by the contractor that the provider meets the requirements of an authorized TRICARE provider under 32 CFR 199.6.
10.5.5  Provide in writing of the reinstatement date, once the determination is made that the provider meets the requirements of a TRICARE Authorized provider under 32 CFR 199.6.
10.5.6  If pharmacy, provide in writing that the pharmacy has met the state licensing requirements and advise the pharmacy of the date it is eligible to negotiate a new network agreement with the contractor, as determined by DHA.
10.6  The contractor shall notify the provider in writing with an explanation on why the provider did not meet the requirements and advise the provider of their appeal rights if the provider does not meet the requirements of a TRICARE Authorized Provider under 32 CFR 199.6.
10.6.1  The contractor shall provide DHA PI a copy of the letter within seven calendar days.
10.6.2  The contractor shall provide in writing to the pharmacy within seven calendar days, that the pharmacy does not have the required state licenses and provide notification to the pharmacy why the pharmacy is not eligible to be a network pharmacy and advise pharmacy of appeal rights.
10.6.3  A copy of the letter shall be provided to the DHA PI within seven calendar days.
10.6.4  The contractor shall provide notification to Beneficiary Counseling and Assistance Coordinators (BCACs) at Markets/Military Medical Treatment Facilities (MTFs) within the provider’s service area of provider status within seven calendar days.
11.0  CONFLICT OF INTEREST
11.1  The contractor shall document and refer suspected violations of conflict of interest to the DHA PI within 15 calendar days.
11.1.1  Conflict of interest includes any situation where an active duty member of the Uniformed Services (including a reserve member while on active duty, active duty for training, or inactive duty training) or civilian employee (which includes employees of the Department of Veterans Affairs/Veterans Health Administration (DVA/VHA)) of the US Government, through an official federal position has the apparent or actual opportunity to exert, directly or indirectly, any influence on the referral of beneficiaries to himself or herself or others with some potential for personal gain or the appearance of impropriety.
11.1.2  Although individuals under contract to the Uniformed Services are not considered employees, such individuals are subject to conflict of interest provisions by express terms of their contracts and, for purposes of the 32 CFR 199.9 may be considered to be involved in conflict of interest situations as a result of their contract positions.
11.1.3  In any situation involving potential conflict of interest of a Uniformed Service employee, the Director, DHA, or a designee, may refer the case to the Uniformed Service concerned for review and action.
11.2  Federal Employees And Active Duty Military
11.2.1  32 CFR 199.6 prohibits active duty members of the Uniformed Services or employees (including part-time or intermittent), appointed in the civil service of the US Government, from authorized TRICARE provider status.
11.2.2  This prohibition applies to TRICARE payments for care furnished to TRICARE beneficiaries by active duty members of the Uniformed Services or civilian employees of the Government.
11.2.3  The prohibition does not apply to individuals under contract to the Uniformed Services or the Government.
11.3  Exceptions
11.3.1  National Health Service Corps
TRICARE payment may be made for services furnished by organizations to which physicians of the National Health Service Corps (NHSC) are assigned. However, direct payments to the NHSC physician are prohibited by the dual compensation provisions.
11.3.2  Emergency Rooms
11.3.2.1  Any off-duty Government medical personnel employed in an emergency room of an acute care hospital will be presumed not to have had the opportunity to exert, directly or indirectly, any influence on the referral of TRICARE beneficiaries; therefore, TRICARE payments may be made to the employing hospital provided the medical care was not furnished directly by the off-duty Government medical personnel in violation of dual compensation provisions.
11.3.2.2  The contractor shall not cost-share professional services by the provider since they cannot be recognized as TRICARE-authorized providers.
11.3.3  Reserves Generally Exempt
11.3.3.1  Conflict of interest provisions do shall not apply to medical personnel who are Reserve members of the Uniformed Services or who are employed by the Uniformed Services through personal services contracts, including contract surgeons.
11.3.3.2  Although Reserve members, not on active duty, and personal service contract medical personnel are subject to certain conflict of interest provisions by express terms of their membership or contract with the Uniformed Services, resolution of any apparent conflict of interest issues which concern such medical personnel is the responsibility of the Uniformed Services, not the DHA.
11.3.3.3  National Guard and reservists on active duty are not exempt during the period of their active duty commitment.
11.3.4  Part-Time Physician Employees Of The US Government
11.3.5  Referrals From Uniformed Services Facilities
11.3.5.1  Referrals from Uniformed Services facilities to individual civilian providers should, in every practical instance, be made to participating providers. However, referrals of TRICARE beneficiaries by Uniformed Services personnel to selected individual providers in the civilian community when other similar participating providers are available may involve a conflict of interest.
11.3.5.2  The contractor shall document any apparent problem of this nature and refer the case to the DHA PI for investigation.
11.3.5.3  In any situation involving potential conflict of interest of a Uniformed Service employee, the Director, DHA, or a designee, may refer the case to the Uniformed Service concerned for review and action.
12.0  REPORTING PROVIDER REFUNDS - PROVIDER REFUNDS (SINGLE CLAIM AND MULTIPLE CLAIMS)
12.1  Providers have a requirement to return overpayments to the TRICARE program (voluntary or requested). Possible reasons for provider refunds (single or multiple claims) may include: Other Health Insurance (OHI), Third Party Liability (TPL), Payment sent to incorrect provider, Duplicate Payment, Provider Billing Error, or TRICARE overpaid.
12.2  The contractor shall notify DHA PI within 30 business days of receiving reported refund when a Provider Billing Error refund is made to the contractor (single or multiple).
12.3  For reporting submission requirements, see DD Form 1423, Contract Data Requirements List (CDRL), located in Section J of the applicable contract.
13.0  VOLUNTARY SELF-DISCLOSURE
13.1  Congress through the Fraud Enforcement and Recovery Act of 2009 (FERA) amended the False Claims Act (FCA) to cover the identification and return of overpayments to federal programs. Specifically, FERA expanded the scope of the FCA to provide liability for “knowingly” retaining an overpayment. Accordingly, the FCA now imposes liability on any provider who received overpayments (accidentally or otherwise) and then knowingly fails to return the overpayment to the Government. The amended statute allows for knowingly retaining an overpayment to be the sole allegation of a complaint under the FCA. Additionally, failure to timely report and return an overpayment under the amended FCA exposes a provider to liability. This includes TRICARE claims and payments.
13.2  Individuals or entities who wish to voluntarily disclose self-discovered potential fraud to DHA-PI may do so under the Self-Disclosure Program (SDP). Disclosing parties may report by sending to DHA PI or may also report online.
13.3  Non-health care matters, should be reported to the DHA Office of Inspector General (OIG) Hotline, or if military, to the DoD OIG Hotline or the respective military service OIG Hotline.
13.4  Disclosing parties already subject to a Government inquiry (including investigations, audits, or other oversight activities) are not automatically precluded from using the SDP. The disclosure, however, must will be made in good faith and must will not be an attempt to circumvent any ongoing inquiry. Disclosing parties under Corporate Integrity Agreements (CIA) with DHA may also use the SDP in addition to making any reports required in the CIA.
13.5  Disclosing parties are advised that the self-disclosure may be shared with other Federal agencies.
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