News & Analysis as of

Centers for Medicare & Medicaid Services (CMS) Voluntary Disclosure

Proskauer - Health Care Law Brief

CMS Proposes Additional Modifications to the Overpayment Rule Relating to the Deadline for Reporting and Returning Overpayments

In the context of Medicare Advantage (“MA”) reform initiatives, we previously addressed the Centers for Medicare & Medicaid Services’ (“CMS”) December 27, 2022 proposal to amend its regulations set forth at 42 C.F.R. §...more

WilmerHale

Criminal Indictment for Medicare Advantage Fraud

WilmerHale on

The U.S. Department of Justice (DOJ) recently announced a rare criminal indictment involving the Medicare Advantage program—a contrast from DOJ’s more typical use of its civil enforcement authority to pursue similar issues...more

Sheppard Mullin Richter & Hampton LLP

Should my Company Self-Disclose Major Fraud? The Answer is Now Clear

After conducting a thorough and privileged internal investigation, it becomes evident that your Company has overcharged the government over $50 million, and that the fraud was directed by a high-level manager. What do you do...more

Troutman Pepper

DOJ's New Voluntary Self-Disclosure Policy Raises More Questions Than It Answers

Troutman Pepper on

On February 22, 2023, the Department of Justice (DOJ) issued a press release highlighting the new Voluntary Self-Disclosure (VSD) Policy for U.S. Attorney’s Offices (USAOs). The DOJ developed this policy, which is applicable...more

McDermott Will & Emery

Special Report - Medicare Providers Take Note: CMS Streamlines the Stark Law Voluntary Self- Referral Disclosure Protocol, Updates...

McDermott Will & Emery on

In the last few months, the US Centers for Medicare & Medicaid Services (CMS) has made several noteworthy changes and provided a material clarification for providers and suppliers who are subject to the federal physician...more

Foley & Lardner LLP

The Top 10 Things you Need to Know About Voluntary Disclosures and Government Refunds

Foley & Lardner LLP on

In February 2016, CMS issued the highly anticipated Final Rule on reporting and returning Medicare Part A and B overpayments. The Final Rule was meant to clear up some of the confusion among providers regarding such...more

Cooley LLP

The Deadline for Submitting Comments Regarding the Self-Referral Disclosure Protocol Is Fast Approaching

Cooley LLP on

On May 2, 2014, the Centers for Medicare and Medicaid Services (“CMS”) published a request for comments relating to the Self-Referral Disclosure Protocol (“SRDP”). The SRDP is a voluntary self-disclosure instrument that...more

Baker Donelson

Comments Due for New Expedited Review Process for CMS's Voluntary Self-Referral Disclosure Protocol (SRDP)

Baker Donelson on

The creation of the SRDP through the Affordable Care Act as a mechanism to resolve potential Stark violations was welcomed by the industry. However, since enactment of the regulations implementing the SRDP in 2010, the volume...more

Baker Donelson

CMS Issues FAQs Regarding Self-Referral Disclosure Protocol

Baker Donelson on

CMS has released its responses to eight frequently asked questions [PDF] regarding its Self-Referral Disclosure Protocol (SRDP). The questions fall into three categories, listed below, and respond to issues that are often...more

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