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Oz: When I start using more words than you, be afraid. The new protocol could be clearer, and could offer more comfort -- but it doesn't.  Makes one pine for the old policy's clarity: in the old days, voluntary disclosure bought you a discounted fine for Stark violations -- not like the new protocol's wishy-washy maybe-we'll give-you-a-discount language.  The new protocol also fails to help a provider seeking to disclose past wrongs voluntarily in dealing with the Federales on a number of fronts simultaneously (e.g., for false claims violations, anti-kickback violations, etc., all arising from the same set of facts).  We can perhaps blame Congress for that failure, rather than the OIG; the OIG's just implementing the statute as written. MVC Contrib A CAREER OF EVOCATIVE YEARS