Updated Procedures for Self-Reporting Stark Law Violations
The Stark Law is a strict liability statute.
Beginning on June 1, 2017, providers must use specific forms published on the Centers for Medicare and Medicaid Services website in order to utilize the Voluntary Self-Referral Disclosure Protocol to self-disclose actual or potential violations of the Physician Self-Referral Law (commonly referred to as the Stark Law). While voluntary disclosures do not eliminate the financial penalties that may result from an enforcement action, they do offer significant benefits that should be taken into consideration when deciding whether to self-report a violation of the Stark Law.
Harold draws on his extensive trial and appellate practice to help pharmacies, pharmacists and other health care providers resolve their most pressing business and regulatory disputes. Harold provides effective compliance and litigation counsel in the full range of industry issues, including disciplinary and licensing matters, self-referral, the Stark Law and the Anti-Kickback Statute, prescription-drug marketing laws, and contract disputes.
Over the course of his career, Harold has argued cases in state and federal district and appeals courts across the country. In addition to his work in the health care arena, he has represented numerous publicly traded, privately owned and closely held companies operating in a broad spectrum of industries such as real estate, retail and professional services. Harold has advised clients in commercial disputes involving real estate brokerage, development and leasing, changes of control and ownership, trade secrets, employment and consulting agreements, and commercial contracts and warranties.
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