Stark law prior-disclosure settlements nearly double in 2024

In 2024, CMS settled an agency record of 314 Stark law self-disclosures, with settlement amounts totaling over $24.7 million. 

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Here are five things to know about the settlements, according to a Feb. 24 news release by CMS:

1. The $24.7 million in settlement collections is nearly double its 2023 Stark law settlement collections of $12.2 million.

2. CMS settled more self-disclosures in 2024 than it had settled for 2023 and 2022 combined, and almost as many as it had in total for the entire first decade of the protocol.

3. CMS’ record-breaking year for Stark law disclosure settlements is evidence of the agency’s efforts to work through self-referral disclosure protocol submissions more efficiently than in the past, according to the report. 

4. The average settlement amount in 2024 was $78,781, which lands within the average range of settlements between 2016 and 2023. 

5. Fifty-one self-referral disclosure protocol submissions were withdrawn in 2024.

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