CMS updated its voluntary self-referral disclosure laws Jan. 23, according to law firm Nexsen Pruet in a Feb. 15 article on JDSupra.
Here is what physicians and ASCs need to know:
1. The updates include an updated version of the self-referral disclosure protocol form, an updated physician information form and a new group practice information form.
2. The new self-referral disclosure protocol form includes an update to signed certification — it no longer needs to be submitted as a hard copy and can now be submitted electronically.
3. The group practice information form includes questions that are specific to physician practices and failed to previously qualify as a Stark Law "group practice," the report said. The new form should be completed only by physician practices that are reporting the failure to qualify as a group practice under Stark Law.
4. The recent rulemaking indicates a significant portion of the self-referral disclosures CMS received involved noncompliance with group practice requirements that are "detailed, nuanced and include compensation restrictions that can be counterintuitive for physicians and physician practices," according to the report.