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Stark Self-Disclosure: What, Why, Where, When (Update on 60-Day Rule), and How


Tuesday, February 26, 2013

This webinar is brought to you by the Hospitals and Health Systems Practice Group, and is co-sponsored by the Business Law and Governance;  Fraud and Abuse; Healthcare Liability and Litigation; and In-House Counsel Practice Group.


This webinar will address the following:

  • How to determine if/when a federal Stark Law violation has occurred and if/when a contract compliance self-audit is necessary or appropriate;

  • Understanding why the penalties under laws such as the federal Anti-Kickback Statute, the federal Stark Law, and the mini-Stark laws and mini-Anti-Kickback statutes make such self-audits important;

  • How to conduct a compliance self-audit, including setting appropriate parameters.

  • Establishing guidelines for allocating responsibility among the team members (including in-house departments and, if applicable, external legal counsel);

  • Once a self-audit is complete, under what circumstances should self-disclosure be considered?;

  • Principal advantages and disadvantages of the various self-disclosure protocols and options (e.g., fiscal intermediary/contractor, U.S. Department of Justice, Office of Inspector General , and Centers for Medicare & Medicaid );

  • Understanding updates to the 60-day rule and the “look-back” period;

  • Lessons learned from recent self-disclosures; and

  • How can contract compliance programs and other initiatives and efforts prevent future issues.



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