In 2024, seven major Stark law indictments contributed to a record-breaking 979 qui tam lawsuits, with False Claims Act settlements and judgments totaling $2.92 billion by the federal government’s fiscal year-end.
The enforcement wave was built across five years of escalating DOJ activity, record self-disclosure settlements and whistleblower cases that have rewritten the compliance calculus for physician compensation arrangements.
Here are five of the biggest Stark law cases from the last five years:
Community Health Network: $480 million
In the largest Stark law enforcement action in DOJ history, resolved in two installments, Indianapolis-based Community Health Network agreed to a $345 million settlement in December 2023 to resolve allegations dating back to 2008 that it violated the False Claims Act and Stark law. The case stemmed from a whistleblower complaint filed in 2014 by the system’s former CFO and COO. The government alleged the system’s senior management recruited cardiologists, cardiothoracic surgeons, vascular surgeons, neurosurgeons and breast surgeons with compensation well above fair market value, with bonuses tied to referral volume.
In January 2025, Community paid an additional $135 million to settle the remaining portion of the same whistleblower case, bringing the total to $480 million. The case established that fair market value opinions from outside consultants are necessary but not sufficient, meaning if compensation is structured to reward referral volume, the DOJ will pursue it regardless of what an appraisal says.
Covenant HealthCare: $69 million
Saginaw, Mich.-based Covenant HealthCare and two physicians paid $69 million in three civil settlements in March 2023 for allegedly improper arrangements with referring physicians. Among the claims, Covenant allegedly entered into contracts with physicians to serve as medical directors that did not satisfy any Stark law exceptions. The case put medical director contracts under direct scrutiny. Nominal or above-market payments structured around physicians who generate significant referral volume will draw attention regardless of how the arrangement is labeled.
St. Francis Health: $36.5 million
Columbia, S.C.-based St. Francis Health agreed to pay $36.5 million in June 2023 to resolve allegations it violated Stark law by making payments to orthopedic surgeons tied to the volume or value of referrals.
Detroit Medical Center: $29.7 million
Detroit Medical Center agreed to pay roughly $29.7 million in May 2023 to settle claims from a former employed physician. The government alleged the health system provided services of non-physician practitioners at no cost or below fair market value to physicians to induce referrals. The case expanded the compliance conversation beyond salary arrangements to include in-kind support — staffing, administrative services and other non-cash benefits provided to referring physicians.
NewYork-Presbyterian/Brooklyn Methodist: $17.3 million
NewYork-Presbyterian/Brooklyn Medical Methodist Hospital agreed to pay $17.3 million in February 2023 to resolve allegations it paid unlawful kickbacks to physicians. The hospital allegedly made payments to physicians at its chemotherapy infusion center where physician compensation was linked to the number of referrals made for services at the center.
Massachusetts Eye and Ear: $5.7 million
Boston-based Massachusetts Eye and Ear agreed to pay more than $5.7 million to settle allegations that parts of its physician compensation models violated Stark law. The hospital allegedly paid an affiliated physician group a percentage of its operating margin from facility fees, with the physician group then distributing a portion of those funds as bonuses to employed physicians based on performed services or hours worked. The case established that routing facility fee revenue back to physicians through bonus structures, even when framed as productivity pay, can trigger Stark liability.
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