The Centers for Medicare and Medicaid Services’ (CMS) Self-Referral Disclosure Protocol (SRDP) outlines a process for providers to disclose to CMS potential or actual violations of the Stark law. In an effort to streamline the self-disclosure process, CMS has issued new SRDP Forms for use by providers of services and supplies when disclosing actual or potential violations of the Stark Law under the SRDP. At this time, the use of the new SRDP Forms is voluntary. However, effective June 1, 2017, providers will be required to use the SRDP Form in connection with a disclosure under the CMS SRDP.
There’s a limited exception to use of the SRDP Forms for physician-owned and rural hospitals, which is explained in CMS’s special instructions. CMS also clarified that for disclosures of noncompliant financial relationships involving more than one physician, the disclosing provider is required to submit a separate Physician Information Form for each physician. Information on the SRDP and the use of the SRDP Forms can be found on CMS’s SRDP web page.