Financial Relationship

On March 28, the Centers for Medicare & Medicaid Services (CMS) revised the procedures and posted new forms for its Voluntary Self-Referral Disclosure Protocol (SRDP).  The SRDP is a mechanism established pursuant to the Affordable Care Act for health care providers and suppliers to facilitate settlement of violations of the physician self-referral law (Stark Law).

Under the Stark Law, physicians (or their immediate family members) who have a financial relationship with an entity are prohibited from making referrals to that entity for certain designated health services (DHS) that are payable by Medicare, unless an exception applies.  In addition, the entity is prohibited from presenting (or causing to be presented) claims to Medicare, or another individual, entity or third-party payer, for the services referred in violation of the Stark Law.  Violations of the Stark Law can result in monetary penalties of $10,957 to $21,916 per claim submitted. 
Continue Reading CMS Revises Process for Reporting Stark Law Violations and Posts New SRDP Forms