Stark Voluntary Self-Referral Disclosure Protocol

Section 6409 of the Patient Protection and Affordable Care Act (PPACA) required CMS to develop a Medicare Self-Referral Disclosure Protocol (SRDP) to facilitate the resolution of potential Stark violations. The SRDP was published on September 23, 2010 with two caveats:

1.         Despite the fact that potential violations or situations might violate more than just the Stark