Providers have embraced CMS's Stark law disclosure process, a CMS official said at a conference I attended this week. Troy Barsky, the director of CMS's Division of Technical Payment Policy, said CMS has received 18 submissions under the Stark self-referral disclosure protocol (SRDP) through the first three months of 2013, and he said the agency expects to receive roughly 100 for the entire year.

Speaking at the American Health Lawyer's Institute on Medicare and Medicaid Payment Issues, Barsky said the SRDP has become much more popular than CMS expected when it was first launched in September of 2010. Barsky said CMS has received a total of 258 disclosure submissions since 2010. Out of the 258 disclosures, CMS has settled with 19, he said.

He also said providers have become much more organized in their submissions. "We used to get boxes of documents, now we get organizes binders," Barsky said.