Please be advised that contacting Ruder Ware by e-mail does not create an attorney-client relationship. If you contact the firm by e-mail with respect to a matter where the firm does not already represent you, any information which you disclose to us may not be regarded as privileged or confidential.


Accept   Cancel

Please be advised that contacting Ruder Ware by e-mail does not create an attorney-client relationship. If you contact the firm by e-mail with respect to a matter where the firm does not already represent you, any information which you disclose to us may not be regarded as privileged or confidential.


Accept   Cancel

PAL Login

linkedin.jpgyoutube.jpgvimeo.jpgtwitter_off.png View Ruder Ware

Health Care Blog

Reminder: New Voluntary Self-Referral Disclosure Effective June 1

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.  More information, including the SRDP forms, is available here.  https://www.cms.gov/medicare/fraud-and-abuse/physicianselfreferral/self_referral_disclosure_protocol.html

This new disclosure process is not applicable to all (e.g. physician-owned hospitals and rural hospitals).  Please contact us if you have any questions regarding the new disclosure process or whether it is applicable to you.