The Centers – Implementation of the Self-Referral Disclosure Protocol (SRDP) and its status after the first several months of operation are described in a report submitted to Congress on March 23, 2012 by the Secretary of the Department of Health and Human Services (DHHS). Section 6409 of the Affordable Care Act directed the Secretary to establish the SRDP, authorized the agency to reduce amounts due and owing for actual or potential violations of the Stark law disclosed under the SRDP, and required the Secretary to submit a report to Congress on the implementation of the SRDP no later than 18 months after the date on which it was established. The report provides some additional insight as to the workings of this disclosure and settlement process, although the final publicized settlements remain sparse.
The SRDP was established on September 23, 2011, and the report covers the period from that date through early March 2012. The report indicates that during that period, a total of 150 disclosures were submitted to CMS, with most of those submitted during the year 2011. Hospitals accounted for 125 of these submissions, with the other disclosures filed by clinical labs, group practices, community mental health centers, DME suppliers, and one ambulance company.
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