Here are four cases involving alleged Stark law violations Becker’s has reported on in 2025:
1. Buffalo, N.Y.-based Catholic Health System agreed to pay more than $3.29 million to settle allegations that it submitted false Medicare claims in violation of the Stark law. According to the Justice Department, Catholic Health System had improper financial arrangements with non-employee physicians who referred services to CHS, which then billed Medicare for those services. The Justice Department said these compensation agreements did not meet Stark law exceptions because they were either not commercially reasonable or exceeded fair market value.
2. Gulfcoast Eye Care, operating under the name Pinellas Eye Care, has agreed to pay $615,000 to resolve allegations of violating the Stark Law and the False Claims Act. Federal investigators claimed that the practice maintained a financial arrangement with a third-party provider that incentivized physicians to refer patients for diagnostic procedures — notably, transcranial Doppler (TCD) ultrasounds. Physicians allegedly received financial benefits tied to the volume of unnecessary TCDs ordered, which were then billed to Medicare and Medicaid. The compensation structure was reportedly based on the volume or value of these referrals, in breach of federal regulations.
3. Community Health System, along with its affiliated management company, Physician Network Advantage (PNA), agreed to pay $31.5 million to settle widespread violations of the Stark Law. According to federal authorities, CHS leveraged PNA to provide financial and other benefits to local physicians as an inducement for patient referrals to CHS hospitals, including Community Regional Medical Center and Clovis Community Medical Center. These arrangements were deemed improper and in violation of federal prohibitions against compensation linked to referral volume.
4. Northwest Anesthesiology and Pain Services reached a settlement over allegations that it violated the Stark Law and the False Claims Act by accepting improper bonus payments. Between January 2019 and December 2021, the group allegedly received approximately $1.8 million in bonuses tied to services billed to Medicare by independent pain management practices. The arrangement failed to meet federal criteria for lawful compensation structures.
