There’s been no shortage of hospital civil monetary penalty (CMP) settlements for alleged Stark and kickback violations, most of them stemming from self-disclosures. The HHS Office of Inspector General rolled out a number of them in late December, and the settlement amounts aren’t small potatoes. For example, Westfields Hospital in Wisconsin agreed to pay $204,150 to resolve allegations that it violated the CMP law in connection with providing space, services and supplies to four physician group practices without entering into a formal written contract. A lawyer for the hospital didn’t return calls for comment. In another case, three West Virginia hospitals — City Hospital, Inc., Jefferson Memorial Hospital and West Virginia University Hospitals-East — agreed to pay $949,595 to settle a Stark and kickback-related CMP. The lawyer for the West Virginia hospitals also had no comment. These are only two of several CMP settlements for Stark and kickback problems unveiled in December.
Does this mean compliance programs are becoming more effective at identifying violations? Are hospitals satisfied with their self-disclosure experiences? What is the significance of the big-dollar settlements?