Health Law Blog - Healthcare Legal Issues

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.

Random Posts


Tags: , ,

Comments are closed.

John H. Fisher

Health Care Counsel
Ruder Ware, L.L.S.C.
500 First Street, Suite 8000
P.O. Box 8050
Wausau, WI 54402-8050

Tel 715.845.4336
Fax 715.845.2718

Ruder Ware is a member of Meritas Law Firms Worldwide

The Health Care Law Blog is made available by Ruder Ware for educational purposes and to provide a general understanding of some of the legal issues relating to the health care industry. This site does not provide specific legal advice and you should not use the information contained on this site to address your specific situation without consulting with legal counsel that is well versed in health care law and regulation. By using the Health Care Law Blog site you understand that there is no attorney client relationship between you and Ruder Ware or any individual attorney. Postings on this site do not represent the views of our clients. This site links to other information resources on the Internet; these sites are not endorsed or supported by Ruder Ware, and Ruder Ware does not vouch for the accuracy or reliability of any information provided therein. For further information regarding the articles on this blog, contact Ruder Ware through our primary website.