Where should disclosures indicating criminal liability be submitted?

Disclosures indicating criminal liability should be submitted to the Department of Justice (DOJ). The DOJ is the federal agency responsible for enforcing the law and overseeing legal proceedings related to criminal activity, including health care fraud. When there is evidence or suspicion of criminal conduct, it is crucial to notify the DOJ as they have the authority to investigate and prosecute such cases.

Submitting disclosures to internal legal counsel may be appropriate for seeking legal advice or guidance, but it does not fulfill the requirement of reporting to a law enforcement agency that can take direct action. The Federal Trade Commission (FTC), while involved in consumer protection and preventing unfair business practices, is not the primary agency for addressing criminal liability in healthcare. Local police departments typically handle law enforcement at the community level, but health care fraud cases generally involve federal jurisdiction, thus making the DOJ the appropriate reporting entity for such disclosures.