Health Law Alert: CMS Publishes Self-Referral Disclosure Protocol Settlements


The Centers for Medicare and Medicaid Services (CMS) publishes short summaries of settlements with health care providers as a result of the Self-Referral Disclosure Protocol (SRDP). The SRDP permits health care providers to voluntarily disclose violations of the federal physician self-referral law, also called the Stark law. CMS  published the SRDP in September 2010. Since that time, CMS has published thefollowing four settlements:

1. An acute care hospital located in Massachusetts settled potential violations in February 2011 involving the use of the Stark law's personal services arrangement exception (42 C.F.R. § 411.357(d)) for hospital department chiefs, medical staff leadership positions, and physician groups that provided overnight coverage at the hospital. The settlement amount was $579,000.

2. On November 9, 2011, a Mississippi critical access hospital settled self-reported violations involving the personal services arrangement exception and certain hospital and emergency room physicians. The hospital paid $130,000 to settle the violations.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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