Stark Law Self Disclosures Through 2013
Thursday, April 17th, 2014Self Disclosure Under Stark Law – Disclosures Made and Settled Through 2013
CMS 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.