In a short three-week period, the U.S. Department of Justice announced three large, multi-million dollar False Claims Act settlements involving Stark Law violations. Each of the three cases alleged that health systems compensated physicians in excess of fair market value, and in excess of collections for services personally performed by those physicians, in order to induce referrals. Although the whistleblowers in each of the cases alleged a broad array of fraud and abuse issues, this summary focuses on those related to physician compensation.

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