Navigating CMS' New Self-Referral Disclosure Protocol

Law360, New York (November 9, 2010, 1:27 PM EST) -- Based on a congressional mandate included in the Patient Protection and Affordable Care Act,[1] or the ACA, the Centers for Medicare & Medicaid Services published a document entitled “the CMS Voluntary Self-Referral Disclosure Protocol” on its website on Sept. 23.[2]

Establishment of the SRDP, which sets forth a process for self-disclosure of actual or potential violations of the Stark Law, is significant because the CMS previously had no such protocol or process in place.[3] Congress presumably intervened because the Office of Inspector General for the U.S....
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