Regulators haven’t touched the Stark law’s core rules in years, but enforcement hasn’t slowed down.
Record False Claims Act recoveries, a surge in whistleblower suits and a growing wave of self-disclosures all point to a compliance environment that’s only getting tighter.
Here’s Stark law enforcement in 10 numbers:
1. $6.8 billion. How much the Justice Department recovered under the False Claims Act in fiscal year 2025 — the highest annual total in the law’s 160-year history and more than double the 10-year average, according to the DOJ.
2. 84%. The share of that $6.8 billion, more than $5.7 billion, tied to healthcare fraud, according to a DOJ recap from Morgan Lewis, reinforcing that hospitals, health systems and physician practices remain the government’s top target.
3. 1,297. The number of new qui tam whistleblower lawsuits filed in fiscal year 2025, which is a record that broke fiscal year 2024’s mark of 980 suits, which was itself a record at the time.
4. $535. The maximum non-monetary compensation an entity can give a referring physician annually under the Stark law’s limited remuneration exception in 2026, up from $519 in 2025.
5. 40+. The number of exceptions built into the Stark law, each with its own technical documentation requirements.
6. 176. The number of Stark law self-disclosures CMS resolved in 2023, the most recent year with published data, a 552% jump from the 27 disclosures resolved in 2021, totaling $12.56 million in resolved payments.
7. $480 million. What Indianapolis-based Community Health Network has now paid to resolve Stark law allegations tied to physician compensation — $345 million in a 2023 settlement plus another $135 million in January 2025 — making it one of the largest Stark-related recoveries on record.
8. $38 million. UPMC’s 2024 settlement over claims that 13 neurosurgeons were compensated based on referral volume rather than services actually performed or supervised; more than $11 million of that went to the whistleblowers who brought the case.
9. $615,000 to $31.5 million. The range of settlements across the six Stark law cases Becker’s tracked over the past year, spanning eye care, anesthesiology, pain management and hospital-physician compensation arrangements.
10. 4. The number of years since regulators last made a major overhaul to Stark law rules, even as enforcement activity and settlement dollars keep climbing.
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