Md Stark SRDP Self Disclosure

An answer that survives a Stark self-referral audit.

Potential Stark Law self-referral violation and build a CMS Self-Referral Disclosure Protocol (SRDP) submission strategy.

In your hands by Friday. With the cite trail attached.

Three Stark-Law Exception Categories + Statutory Spine

42 USC 1395nn is strict-liability self-referral. Compliance routes through one of three exception families under 42 CFR Part 411.

1. 1
   Compensation arrangement exceptions - 42 CFR 411.357

   Rental, employment, personal services, FMV. Each requires written, signed, FMV, set-in-advance, referral-blind compensation.
2. 2
   Ownership and investment interest exceptions - 42 CFR 411.356

   Publicly traded securities (NYSE / NASDAQ), regulated investment companies, rural providers. Narrow, structural.
3. 3
   Designated health service general exceptions - 42 CFR 411.355

   In-office ancillary services, group-practice services, academic medical center, EHR / cybersecurity donation safe harbors.
4. 4
   Statutory spine: 42 USC 1395nn (Stark Law itself)

   Strict-liability self-referral ban. Civil monetary penalties + denial of payment. SRDP self-disclosure under 42 CFR 411.389.

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