Extract to table

OIG SDP Submission Requirements A complete SDP submission must include a detailed written narrative and supporting documentation sufficient to allow the OIG to evaluate the nature and scope of the disclosed conduct

These benefits must be weighed against the risks and costs of filing, as discussed in Section III

Risks and Costs of Filing The decision to file an SDP submission is not without significant risks and costs, which must be carefully weighed against the potential benefits

The arrangement accordingly falls outside the protection of any recognized safe harbor and must be evaluated under the general AKS prohibition