Articles and Blogs

Self-Referral Disclosure Protocol

The Stark Law Payments by a Physician Exception: An Unsung Hero

[05/02/25]

Posted on May 2, 2025 in Health Law News

Published by: Hall Render

Historically, health care entities looking to avoid potential violations under the Federal Stark Law (“Stark”) have not turned to the Payments by a Physician exception at 42 C.F.R. § 411.357(i) to protect their operations. A review of the exception’s history, however, combined with recent experience with pending submissions to the Centers for Medicare &... READ MORE

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CMS Proposes Revised Process for Group Practices Self-Disclosing Stark Law Violations

[06/29/22]

Posted on June 29, 2022 in Health Law News

Published by: Hall Render

On June 9, 2022, the Centers for Medicare & Medicaid Services (“CMS”) published a notice seeking public comment on its plan to revise the way information is collected under its voluntary Self-Referral Disclosure Protocol (“SRDP”). Specifically, the proposed rule would allow a group practice to submit a single “Group Practice Information Form” that would cover all... READ MORE

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DOJ Self-Disclosure and Cooperation Credit

[05/17/19]

Posted on May 17, 2019 in Compliance, False Claims Act Defense

Published by: Hall Render

The DOJ’s recent revisions to its Justice Manual created a new path for self-disclosing potential fraud to the government – one which is unique in its ability to defray the costs of potential False Claims Act violations. In 2015, Deputy Attorney General Sally Quillian Yates released a memo entitled Individual Accountability for Corporate Wrongdoing, more... READ MORE

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