Reminder: New Voluntary Self-Referral Disclosure Effective June 1

May 31, 2017

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:

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.

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