The Self-Referral Disclosure Protocol: Settlement and Enforcement Trends (Presentation)


The Self-referral Disclosure Protocol (SRDP) permits health care providers to voluntarily disclose violations of the federal physician self-referral law, also called the Stark law. Emily Wein has presented a webinar discussing the background of the SRDP, requirements for participation, and the opportunities it affords to health care providers.

In This Presentation:

OIG’s Self Disclosure Protocol:

• Established in 1998 by the Office of Inspector General (OIG)

• Open and cooperative process for health care providers’ resolution of potential fraud (anti-kickback)

• Technical payment errors are outside scope of protocol

• Demonstrates diligence and good faith

• Lesser sanctions expected

• No Corporate Integrity Agreement (CIA)

• No settlements less than $50,000 for anti-kickback violations

• 2009 – no longer accepted disclosures of only potential Stark violations – will accept if connected to anti-kickback issues

Please see full presentation below for more information.

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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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