Understanding CMS Self-Referral Disclosure Protocol

Law360, New York (October 15, 2010, 3:34 PM EDT) -- On Sept. 23, 2010, the Centers for Medicare and Medicaid Services (CMS) issued its Voluntary Self-Referral Disclosure Protocol (SRDP), under which health care providers may report actual or potential violations of the federal Stark law (42 U.S.C. § 1395nn).

The CMS’s actions came in response to Section 6409 of the Patient Protection and Affordable Care Act of 2010 (PPACA), which required it to issue a disclosure protocol by that date. However, while the CMS has met the congressional mandate, it has offered no assurances to health...
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