Stark Self-Disclosures: Understanding and Working with CMS's New Self-Referral Disclosure Protocol

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