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The Centers for Medicare & Medicaid Services recently announced 2020 settlements concerning past violations or potential violations of the physician self-referral law (the Stark Law) and the number and value of such settlements have returned to the pre‑2019 trends. The 2020 settlements based on voluntary submissions submitted several years ago mark an increase from 2019’s report when CMS announced the lowest aggregate settlement dollars collected since the Stark Law disclosure’s first year in 2011. McGuireWoods speculated last year that such decrease could continue in 2020 as the agency’s attention focused on the pandemic. That said CMS doubled its 2019 settlement numbers, and announced the greatest aggregate settlement dollars collected since reaching aggregate value that peaked in 2016.

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