DOJ healthcare enforcement actions, explained.

Plain-English summaries of major Stark Law and Anti-Kickback Statute settlements. What happened, what it means for your arrangements, sourced from DOJ press releases and federal-court dockets. Updated periodically; last reviewed 2026-05-06.

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$556M
Kaiser Permanente Affiliates — MA Risk-Adjustment Settlement
2026 · N.D. Cal. · FCA · Medicare Part C
The largest MA risk-adjustment FCA recovery on record. Kaiser allegedly mined past medical history to add unsupported diagnosis codes via provider queries and addenda — with quotas and no symmetric deletion of unsupported codes. $95M relator share.
MA risk adjustmentDocumentation asymmetry
Up to $98M
Independent Health — MA Risk-Adjustment Settlement
2024 · W.D.N.Y. · FCA · Medicare Part C · 5-year CIA
Independent Health stood up wholly-owned subsidiary DxID to conduct retrospective chart review and "nudge" providers to file addenda. Settlement capped at $98M (ability-to-pay structure), plus a five-year CIA and personal liability for the DxID CEO.
MA risk adjustmentVendor liabilityCIA
$62.85M
Seoul Medical Group — MA Risk-Adjustment Settlement
2025 · C.D. Cal. · FCA · Medicare Part C
SMG submitted fabricated diagnoses for two high-risk-score spinal conditions, declined the audit subsidiary's correction recommendation, then acquired and terminated it. Engaged a radiology co-conspirator to generate supporting reports. $1.76M CEO personal liability.
MA risk adjustmentFabricated diagnosesCo-conspirator
$1.3B
Esformes Skilled-Nursing Kickback Scheme
2019 · S.D. Fla. · AKS
Cash bribes to physicians and patient recruiters drove a 20-year sentence and the largest individual healthcare-fraud penalty on record.
AKSCash bribes
$623M
Olympus Corporation of the Americas
2016 · D.N.J. · AKS
Free equipment, training, and foreign travel offered to hospitals and physicians as inducements for medical-device purchases.
AKSEquipment inducement
$513M
Tenet Healthcare / HMA Settlement
2016 · N.D. Ga. · Stark + AKS
Fabricated FMV opinions and above-market consulting fees converted referral relationships into $513M of tainted Medicaid claims.
FMV driftStarkAKS
$345M
Community Health Network — Stark Law Settlement
2023 · S.D. Ind. · Stark · 5-year CIA
Largest Stark FCA settlement at announcement. CHN fed valuation firms false compensation inputs, then ignored the "staggering"-and-"high" warnings that came back anyway. Volume-tied bonuses on recruited cardiology, cardiothoracic, vascular, neurosurgery, and breast specialists.
FMV driftStarkValuation manipulationCIA
$85M
Halifax Health Medical Director Settlement
2014 · M.D. Fla. · Stark
Six oncology medical-directorship agreements paid bonuses tied to referral volume, breaching Stark's prohibition on volume-based compensation.
Medical directorshipVolume/value
$72.4M
United States v. Tuomey Healthcare System
2015 · D.S.C. · Stark
Part-time employment agreements with 19 specialists effectively compensated them for referrals; the largest Stark FCA verdict at the time.
FMV driftStark
$69.5M
North Broward Hospital District
2015 · S.D. Fla. · Stark
Nine employed physicians' compensation systematically exceeded their personally-collected revenue, signaling pay tied to referral volume.
Comp exceeds collections
$65M
Prime Healthcare ER Admit Scheme
2018 · C.D. Cal. · Stark
Emergency-department medical directors received bonuses tied to admission rates, creating a financial incentive to admit rather than treat-and-release.
Medical directorshipVolume/value
$50M
Wheeling Hospital Cardiology Division
2020 · N.D.W. Va. · Stark
Compensation paid to high-referring cardiologists materially exceeded contemporaneous market benchmarks without supporting FMV opinions.
FMV drift
$38M
UPMC Neurosurgery — Stark Law Settlement
2024 · W.D. Pa. · Stark · DOJ declined intervention
A 12-year qui tam carried by the relator bar alone. Third Circuit's Bookwalter ruling clarified that productivity-labeled bonuses fail Stark Law when total compensation correlates with referral volume regardless of formula label. $11M relator share across three relators.
FMV driftStarkVolume/valueDOJ declinedAppellate precedent
$31.5M
Fresno Community Health + PNA — AKS/Stark Settlement
2025 · E.D. Cal. · AKS + Stark · 5-year CIA
A custom-built "HQ2" wine-and-cigar lounge for referring physicians, EHR subsidies that exceeded the safe-harbor exception, and sham "clinical integration" bonuses. PNA dissolved; CHS entered a 5-year CIA. ~$5M relator share to former PNA Controller.
AKSStarkEHR safe harborNon-cash kickbacksCIA
$28M
Methodist Hospital Memphis
2019 · W.D. Tenn. · Stark
Clinical space leased to a referring oncology group at below-FMV rates, structured to reward referral volume rather than space-cost reimbursement.
Space rentalBelow-FMV
$22M
St. Joseph Medical Center Bonuses
2010 · D. Md. · Stark
Cardiology medical-directorship contracts paid bonuses based on the number of patient admissions referred by the directors.
Medical directorshipVolume/value
$14.25M
Mercy Health — Self-Disclosed Stark Settlement
2018 · HHS-OIG SDP · Stark Law · Six employed physicians
First case in the cohort to demonstrate the HHS-OIG Self-Disclosure Protocol. Internal audit surfaced compensation arrangements with 1 oncologist + 5 internal medicine physicians outside FMV bounds. Settled 6 months before the Bon Secours merger closed — M&A diligence timing implication.
StarkSelf-disclosedM&A timingFMV drift
$9.89M
Memorial Health University Medical Center (Savannah)
2016 · S.D. Ga. · Stark Law · Schaengold qui tam
Former CEO Phillip Schaengold was the qui tam relator — highest-trust whistleblower posture possible. Board-knowledge theory: board minutes and correspondence became enforcement evidence. The "paying physicians at a loss" contribution-margin theory that later informed CHN and Bookwalter prosecution.
StarkCEO relatorBoard knowledgeContribution margin