When should self-disclosure be made to CMS according to compliance guidelines?

Self-disclosure to the Centers for Medicare & Medicaid Services (CMS) should occur when there is clarity that no Anti-Kickback Statute (AKS) matter exists. This indicates a proactive approach to compliance, ensuring that any potential issues are addressed transparently. Engaging in self-disclosure under the right circumstances, particularly when there are no clear violations of the AKS, demonstrates a commitment to ethical practices and a willingness to cooperate with regulatory bodies.

In this context, the importance lies in understanding that self-disclosure is a mechanism that helps health care organizations to be forthright about concerns—even if they believe there is no wrongdoing. This strategy can mitigate risks of future liabilities as it fosters a relationship of trust with CMS.

The other options describe scenarios where self-disclosure may not be as straightforward or beneficial, as they involve potential violations or suspected wrongdoing, which would typically follow a different set of protocols and considerations. Thus, the focus is on promoting compliance through self-disclosure when there is confidence in adherence to regulations, particularly regarding the absence of AKS concerns.