What to know about Stark law's $9.2M record in self-disclosures 

CMS settled a record-breaking $9.29 million in Stark law voluntary self-referral disclosure settlements in 2022, according to recent CMS data.

Here are five things to know:

1. The number of settlements increased from 27 in 2021 to 104 in 2022, with the aggregate amount of settlements increasing from $1.99 million to $9.29 million in a year.

2. As of Dec. 31, an additional 232 disclosures were either withdrawn, closed without settlement or settled by CMS' law enforcement partners.

3. The self-referral process was instated with the Affordable Care Act and allows providers to self-disclose potential violations generally for less than the total liability, according to an Oct. 18 article in JDSupra from law firm Katten Muchin Rosenman. 

4. This rise in disclosures could be due to shifting resources after the COVID-19 pandemic or a sign that CMS is settling submissions faster, according to the article. 

5. Additionally, CMS began to limit the amount of information available to the number and monetary amount of settlements reached, so providers "worried about reputational information … have less to worry about the amount of information CMS made publicly available on its website," the article said. 

 

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