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Stark Law Self Disclosures Through 2013

Self Disclosure Under Stark Law – Disclosures Made and Settled Through 2013

self disclosure protocols 2013 update oigCMS issued its Stark Law self-disclosure protocols in 2010.  Through the end of 2013, there have been a total of 37 self-disclosure settlement with CMS using this process.  Some of the areas covered by self disclosures have included the following:

  • Failure to comply with the personal service exception in connection with electrocardiogram interpretations;
  • Emergency department “on-call” arrangements that did not comply with an exception;
  • Arrangement with physicians to provide utilization review services;
  • Medical director services, medical coding and consulting services, and office space lease;
  • Psychiatric services;
  • Office space rental and support services;
  • Failure to comply with the in-office ancillary services exception;
  • Case management physician advisor services;
  • EKG interpretation, medical director services, and hospital services;
  • Medical director services;
  • Supervision of cardiac stress tests;
  • Emergency call services at an adjacent walk-in clinic;
  • Space rental agreement;
  • Residency program services, electronic health records expert services, medical director services, leadership services;
  • Emergency cardiology call services;
  • Office space rental agreement;
  • Ownership interests in a rehabilitation hospital;
  • Physician recruitment exception;
  • Professional service agreements;
  • Fair market value compensation issue;
  • On-call payment arrangement;
  • Physician recruitment exception;
  • Dental services;
  • Equipment rental;
  • Non-monetary compensation violation;
  • Personal service agreement;
  • DME supply arrangement;
  • On-site overnight coverage violations.

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John H. Fisher

Health Care Counsel
Ruder Ware, L.L.S.C.
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