Reminder: New Voluntary Self-Referral Disclosure Effective June 1

Ruder Ware
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As discussed in a previous blog, beginning on June 1, 2017, health care providers of services and suppliers wanting to voluntarily disclose actual or potential violations of the Stark Law must follow a new process finalized by CMS.  Previously, health care providers and suppliers were able to submit a self-disclosure of an actual or potential Stark Law violation to CMS by sending a letter to CMS.  Beginning June 1, 2017, health care providers and suppliers will be required to submit all information necessary for CMS to analyze an actual or potential Stark violation on a Form CMS-10328.  This form includes a SRDP Disclosure Form, a Physician Information Form (a separate one must be completed for each physician included in the disclosure), a Financial Analysis Worksheet, and a certification.  A disclosing party is still permitted to submit an optional letter with any additional information.  The SRDP and required forms are available here:  https://www.cms.gov/Medicare/Fraud-and-Abuse/PhysicianSelfReferral/Downloads/CMS-Voluntary-Self-Referral-Disclosure-Protocol.pdf
 

This new disclosure process is not applicable to all (e.g. physician-owned hospitals and rural hospitals). 

 

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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