CMS Settles Record Number of Stark Self-Disclosures

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McGuireWoods – In 2022, the Centers for Medicare & Medicaid Services settled a record 104 self-disclosures of potential violations of the physician self-referral law, with settlement amounts totaling over $9,000,000 in the aggregate.

These amounts are nearly quadruple the number and amounts of settlements in 2021 and one more than the previous record number from 2016. The record number and value of settlements in 2022 shows a marked increase from 2020 and 2021, when we speculated that CMS focused greater attention on the COVID-19 pandemic. Coming on the heels of the pandemic, it appears that CMS is working to review a greater number of self-disclosure submissions annually, which may reduce the backlog or the time it takes to have a self-disclosure reviewed.