To Self Disclose or Not? Pros and Cons for Stark Law Violations

Before jumping on the self-disclosure bandwagon for violating Stark law, find out what to expect …

If you believe you've violated Stark law, the CMS and DHHS Office of Inspector General are suggesting you "turn yourself in" to give yourself a better chance to negotiate lower penalties. Is it a better choice to  rely on an internal audit and voluntary repayment, or to prepare for an audit or investigation that may uncover the problem

Join health care attorney Wayne J. Miller Esq., to learn the pluses AND minuses to following the self-disclosure protocol. It's possible you will receive fewer penalties. Will you escape unscathed or come under even greater scrutiny? What are your alternatives?

Learn how to decide whether or not to move ahead with self-disclosure, and what you need to do to prepare.

Wayne J. Miller will cover these essential highlights:

  • New Stark disclosure protocol: Components and details you need to know
  • Types of alleged violations that should be disclosed - and those that may be inappropriate for self-disclosure
  • Protocol procedures: Before, during and after disclosure - prepare now
  • Prior disclosure cases: What to expect based on previous self-disclosure occurrences
  • Should you or shouldn't you? Considerations and facts in deciding whether to disclose
  • What are your options? Alternative scenarios to self-disclosure
  • Best case scenario: How to position your facility or practice for the best outcome


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