Voluntary Disclosure Program / CMS unveils procedures for self-disclosing Stark violations

Article Overview

This article discusses CMS’s Voluntary Self-Referral Disclosure Protocol for providers and organizations that need to report potential Stark law concerns. It explains the purpose of the protocol, the submission process, the types of information CMS expects, and the broader compliance context, including overpayment reporting timing and possible factors CMS may consider when evaluating a disclosure. The piece is relevant to compliance, legal, and revenue integrity teams that handle physician referral arrangements and self-disclosure decisions.