CMS Updates Stark Law Self-Disclosure Protocol Ahead of November Deadline

In a client alert, Thompson Coburn LLP reports that CMS has updated its Voluntary Self-Referral Disclosure Protocol (SRDP), the mechanism providers and suppliers use to voluntarily disclose actual or potential violations of the federal physician self-referral law (Stark Law). The firm outlines changes providers should understand before a November 1, 2026 compliance date tied to the updated protocol. Hospitals, physician groups, and other providers with existing or suspected Stark Law exposure are directly affected, since the SRDP governs how they report violations and negotiate settlements with CMS. The alert emphasizes reviewing the revised protocol now to ensure any pending or future disclosures comply with the new requirements.

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