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CMS ISSUES SELF REFERRAL DISCLOSURE PROTOCOL
By: Jeffrey L. Cohen
The Florida Healthcare Law Firm
The Centers for Medicare and Medicaid Services (CMS) issued its anticipated self referral disclosure protocol (SRDP) on September 23rd. The SRDP is designed to (1) give providers a way for self disclosing self-referral (Stark Law) violations, and (2) paying any associated Medicare overpayment.

The SRDP was mandated by the healthcare reform law. It is striking in many respects, including (a) it is a "voluntary" self-disclosure program, (b) it is not the result of the usual rule making process (which includes a comment period), (c) the scope of information required to be reported is extremely broad, including for instance a detailed description of the violation and all parties involved, and (d) even "technical" violations will likely give rise to significant monetary repayments. Key provisions of the SRDP include:
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