Self-Referral Disclosure Protocol (SRDP)

The House Ways and Means Committee has approved legislation to create an alternative pathway to resolve certain technical violations of the Stark physician self-referral law. The bill, HR 3726, would allow an entity or individual to voluntarily disclose previous inadvertent technical noncompliance (e.g., the arrangement is not signed by one or more parties to

CMS has released a new Self-Referral Disclosure Protocol (SRDP) Form for disclosing actual or potential violations of the physician self-referral law (known as the “Stark Act”) under CMS’s existing self-disclosure process. According to CMS, the streamlined and standardized format “will reduce the burden on providers and suppliers submitting disclosures to the SRDP” and facilitate CMS

CMS has published a notice inviting comments on a revised Medicare Self-Referral Disclosure Protocol (SRDP), which is a vehicle for providers and suppliers to voluntarily self-disclose actual or potential violations of the physician self-referral statute (known as the “Stark Act”).  Under the currently-approved process, a party must provide a financial analysis of overpayments arising from