CMS Releases Stark Law Self-Referral Disclosure Protocol

On September 23, 2010, the Centers for Medicare and Medicaid Services (CMS) released the much-anticipated Self-Referral Disclosure Protocol (“SRDP”), which establishes a process to voluntarily self-disclose actual or potential violations of the Stark law in return for diminished penalties. The Stark law prohibits physicians from referring patients to healthcare entities in which they have a financial relationship unless that relationship meets a Stark exception.

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