Stark Self-Disclosures: Understanding and Working with CMS's New Self-Referral Disclosure Protocol
November 16, 2010
This presentation offered in clear and concise terms what the SRDP says and what it means for an organization’s disclosure obligations and choices going forward.
Topics included:
- How the SRDP relates to the DHHS Office of Inspector General’s (OIG) previously existing self-disclosure protocol
- Whether providers are limited to selecting the OIG in disclosing conduct that potentially implicates both the Stark Law and the Anti-kickback Statute
- How the SRDP impacts disclosures to the US Attorney’s Office
- Whether the disclosure to either CMS or the OIG will suspend PPACA’s 60-day repayment requirement, pending processing of the disclosure
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