The Centers for Medicare and Medicaid Services (CMS) recently published four new frequently asked questions (FAQs) that amend the Stark Self-Referral Disclosure Protocol (SRDP) to provide greater clarity about the interaction of the SRDP with the long-standing Medicare reopening time periods. The SRDP requires parties to report various information regarding the arrangement disclosed, including significant financial information. Specifically, the FAQs state that the "look back" period for the arrangement is the time during which a party was not in compliance with the Stark Law and that disclosing parties must disclose to CMS the entire look back period. However, under this new CMS guidance, a disclosing party must only report and conduct a financial analysis of the improper claims submitted and paid within the applicable Medicare reopening period. This new guidance is highly favorable to providers because the Medicare reopening rules generally only provide for a four-year period for reopenings. Thus, even though the "look back" period may exceed the applicable reopening period, CMS and disclosing parties will begin their settlement discussions with the financial impact resulting from the shorter reopening period. CMS acknowledged that it recently proposed amending the existing reopening rules as part of the proposed rulemaking to implement Section 6402(a) of PPACA and stated that providers may continue to rely on the current reopening time periods when making disclosures through the SRDP until such rules are finalized.