On May 6, 2016, CMS published an information collection request notice regarding the existing Medicare self-referral disclosure protocol (SRDP). Specifically, CMS intends to streamline the current SRDP and revise the information collected by the SRDP for consistency with the February 12, 2016 Reporting and Returning of Overpayments for Medicare Parts A and B Final Rule (Overpayment Final Rule).
CMS states that the agency intends to streamline and simplify the SRDP by requiring use of a standard form for all SRDP submissions. CMS expects that the form will reduce the burden on parties participating in the SRDP by reducing the amount of information required for submission and standardizing the submission format.
In addition, CMS intends to update the SRDP in light of the Overpayment Final Rule. Specifically, CMS will revise the information collected for the SRDP to reflect the six-year lookback period established by the Overpayment Final Rule for those submissions received on or after March 14, 2016. The previous SRDP lookback period was four years.
CMS’s notice is available here. Comments regarding the information collection must be received by July 5, 2016.
Reporter, Lauren S. Gennett, Atlanta, + 1 404 572 3592, lgennett@kslaw.com.