The Centers for Medicare and Medicaid Services (CMS) recently issued a notice of proposed information collection regarding a new form called the Disclosure of Financial Relationships Report (DFRR) and is accepting comments on the form until July 17, 2007.1 Hospitals, physicians, and other health care providers and suppliers should take note because CMS will use the DFRR to survey hospitals concerning their ownership, investment, and compensation arrangements with physicians so that it can analyze their compliance with the Stark law.

In this Mintz Levin Advisory:

Purpose of the DFRR

DFRR Recipients

Information Solicited in the DFRR

DFRR Submission Requirements

Timing and Consequences for Noncompliance

Implications.